C.C. v. J.A.H., ___ N.J. Super. ___ (App. Div. 2020). The Prevention of Domestic Violence Act, N.J.S.A. 2C;25-17 et seq., allows the issuance of a restraining order for the protection of any “victim of domestic violence.” Such victims include “any person who has been subjected to domestic violence by a person with whom the victim has had a dating relationship.” But the statute does not define “dating relationship.” The question in today’s opinion by Judge Rose was whether the parties had a “dating relationship” even though they never went...

In re Adoption of a Child by C.J., ___ N.J. Super. ___ (App. Div. 2020). This opinion, issued today,must have been a very distasteful opinion for Judge Koblitz to write. As will be seen, the bottom line is “to be continued,” so quoting the first paragraph of the opinion in full and inviting readers to look at the rest of the decision for the unfortunate details suffices for today: “We write to emphasize that an attorney has an obligation to inform the court if he or she is not able to handle an assigned matter professionally due to a lack of expertise and inability to...

The Supreme Court announced that it has granted certification in two more cases. One arises out of a finding of child abuse and neglect. The other involves a request for expungement of criminal convictions following a gubernatorial pardon. The former case is New Jersey Department of Child Protection and Permanency v. J.R.-R. and G.R.-R. The question presented, as phrased by the Supreme Court Clerk’s office, is “Among other issues, did the family court apply conditional res ipsa loquit[u]r and improperly shift the burden to the parents to rebut the presumption that they abused or...