The Superior Court of Pennsylvania recently made a decision that will change how Protection from Abuse (PFA) cases will proceed. Previously, as a matter of practice, a PFA petition once filed would be reviewed by the Judge and then a decision could be made as to whether a temporary PFA order was warranted pending a final hearing just based on review of the petition. In Ferko-Fox v. Fox, 2013 PA Super 88 (2013), the Superior Court ruled that the practice of granting temporary orders in this fashion does not meet the requirements of due process as required by the PFA statute. Specifically, 23 Pa. C.S. 6107 (b) requires the court to conduct an ex parte hearing prior to determining if a temporary order is warranted.