Desiato v. Abbott

In Desiato v. Abbott, 261 N.J. Super. 30, 617 A.2d 678 (Ch.Div.1992), the court held that a girlfriend met the jurisdictional requirements of being an alleged victim of domestic violence in light of the family-like setting of the relationship that resulted in the parties being de facto "household members" within the meaning of the Act, even though the parties had never been married or shared the same legal residence. The court in that case construed the term "household member" to require more than a casual dating relationship but less than the parties residing together." Desiato, supra, 261 N.J. Super. at 34, 617 A.2d 678. In reaching its decision the court found that the definitional standard of a "household member" should be measured by the frequency of the time the parties spend together and a variety of other factors. Ibid.