In 2016, Manning was again accused of attacking girlfriend Hollianne Hartman. Hartman sought a domestic restraining order against Manning but was denied due to jurisdictional issues. The attack was one of several that Hartman claimed to have suffered, with the most recent alleged abuse occurring in late 2015 at Manning's Manhattan apartment. Manning's lawyer stated that the application for a restraining order was preceded by stalking and theft charges filed against Hartman and was intended as a distraction from those charges.