In a Decision – D.S. v. C.S. (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that change of custody was proper because defendant’s threats of murder, while not directed at the children, could have serious adverse effects on them.
N.J.S.A. 2C:25-29(b), which allows the court to grant "any relief necessary to prevent further abuse," including modification of "temporary custody of [] minor [children]." Defendant had threatened acts of violence, including murder. While the threats were not directed at the children, such threats could have serious adverse effects on them. In that regard, defendant's daughter testified that her mother was "obsessed" and appeared paranoid.