kill a woman the PFA order explicitly intended to protect. Under the majority's holding, law enforcement officers in similar circumstances would be restricted until a threat is communicated to the intended victim. Only then would it be sufficiently clear that threatening has occurred to constitute a violation of the order. To allow law enforcement officers to stand idly by while a person expresses his intent to kill because the intended victim is not present or has not yet been informed of his intent is absurd and in total contradiction of the Act's purpose to prevent imminent harm. Under the majority's rationale, if after hearing appellant's statement the deputies immediately telephoned Ms. Banks and informed her of what they heard only then would appellant's statement constitute a threat. Thus,his intention to do so does not eliminate the fact he made a threat. Finally, even if appellant was to remain in the York County Prison for an extended period of time, his expression of intention to kill Ms. Banks was an early sign of abuse to which the deputies reacted. Consequently, his statement constituted a threat and was a violation of the PFA order.
While inroads have been made in the judicial arena through PFA orders to protect victims and punish batterers, the majority opinion defeats the efforts targeted by these legal solutions. Victims of domestic abuse inherently rely on indirect criminal contempt sanctions as a remedy for violations of the PFA Act. The contempt road empowers abused victims and helps them escape from the violence. Taking away