In Jasina v Jasina, Docket No. 275583, the Michigan court of appeals held that the trial court properly refused to issue a personal protection order against the Petitioner's brother. The allegation was made, and supported by a tape-recorded telephone conversation, that the Respondent had said "Stay away from me or I will punch you in the head."
The COA panel stated that this was insufficient to support issuance of a PPO since if the Petitioner simply stayed away from his brother, there would be no threat of harm. In other words, as I've heard some characterize such statements, "I'm not making a threat; I am making a promise."