Borough of Glassboro v. Vallorosi

In Borough of Glassboro v. Vallorosi, 117 N.J. 421, 432-33, 568 A.2d 888 (1990), the Court found that a house occupied by ten college sophomores demonstrated sufficient "stability" to constitute "the functional equivalent of a family" for zoning purposes, because "the students ate together, shared household chores, paid expenses from a common fund," and intended to maintain the living arrangement until their graduation from college. Glassboro dealt with a local ordinance's definition of a "single house-keeping unit" for zoning purposes; it is not applicable to current domestic violence law which liberally construes the Act to protect victims so as to include even temporary living arrangements. Bryant v. Burnett, 264 N.J. Super. 222, 624 A.2d 584 (App.Div.1993). In Bryant v. Burnett, supra, 264 N.J. Super. at 224, 624 A.2d 584, plaintiff had been living with defendant for approximately three months because, according to defendant, "plaintiff had no place to stay and he offered her the opportunity to stay at his place as a favor. He did not intend any agreement to live together on any ongoing or permanent basis." Defendant further argued that "even though he and plaintiff had lived together for three months, their intent at that time that the arrangement was 'temporary', deprived plaintiff of standing to bring a complaint under the Act, since she was not a member of his 'household.'" Ibid.