In Lee-Magana v. Carpenter, the supreme court held that prevailing petitioners, although not prevailing respondents, should generally be awarded attorneys’ fees in protective order proceedings. Lee-Magana and Carpenter were in a romantic relationship for approximately two years and had a child together, but split amidst allegations of domestic violence. Lee-Magana petitioned first for protective orders against Carpenter, which were granted. A few weeks after Lee-Magana’s filed those petitions, Carpenter filed for his own protective orders against Lee-Magana, which were denied by the same judge. Having prevailed in both petitions, Lee-Magana moved for attorneys’ fees for each proceeding, which the superior court denied without explanation. On reconsideration, the superior court stood by both of its decisions and explained that it was denying attorneys’ fees for Lee-Magana’s successful defense against Carpenter’s protective order petition out of concern for chilling worthy domestic violence victims’ pursuits of relief. As for Lee-Magana’s successful protective order petition against Carpenter, the superior court explained that, while Lee-Magana sought recovery under a statute that shifted fees in protective order proceedings for domestic violence victims, the hearing at which Lee-Magana ultimately won primarily addressed custody and child support issues. On appeal, the supreme court agreed with the superior court’s policy reasoning as to Lee-Magana’s defense against Carpenter’s petition and added that this was consistent with the relevant statute’s plain text. However, the supreme court built on precedent developed in child support cases to conclude that the superior court erred in not granting attorneys’ fees in Lee-Magana’s successful petition because, based on the statute, withholding attorneys’ fees for prevailing protective order petitioners is proper only in exceptional circumstances. Accordingly, the supreme court affirmed the superior court’s decision to deny attorneys’ fees to Lee-Magana as a respondent, but reversed the decision to deny attorneys’ fees for her successful petition. Affirming the superior court, the supreme court held that attorneys’ fees should generally be awarded to prevailing petitioners, although not prevailing respondents, in protective order proceedings.