In a Decision – A.L.I. v. D.W. (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that a Cousin who was for 10 days at the marital residence and then left with the Wife’s Husband to cohabit, was not a ‘household member’ for purposes of the Domestic Violence statute notwithstanding that this Cousin allegedly spoke abusively to the Wife and physically attacked the Wife.
The trial judge correctly found that the parties were never household members. Although they may have occasionally stayed under the same roof on visits to plaintiff’s mother when they were children or taken vacations together or had overnight visits in each other’s homes over the years, they were never members of the same household.