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Diane Cobb, a member of the United States Armed Forces, resides and works in a federal enclave.' Solely because of this, questions of law arose as to whether a Massachusetts state court could issue a restraining order to protect her and her infant child from an abusive and dangerous civilian husband,2 and whether such a state-generated order even would be enforceable in a federal enclave.3 The jurisdiction of federal courts does not reach into domestic relations.4

Federal Enclaves and Local Law: Carving out a Domestic Violence Exception to Exclusive Legislative Jurisdiction