In a Decision – E.S. v. H.A (a "Reported Decision") >> the Court Held:
The Appellate Division reversed that those provisions of the Court Orders which required the Father to “comply with [certain] requirements” “[p]rior to” making “any application for parenting time” with his son.
the court reversed as to requiring defendant-father to admit his wrongdoing prior to application for parenting time as a violation of his Fifth Amendment rights against self-incrimination. Further, such orders directly threatened defendant-father’s parental rights because he may not petition for modification unless and until he waives his privilege against self-incrimination and admits “wrongdoing.”.