In a Decision – A.R. v. A.C., ,, (an "Unreported Decision") >> the Court Held:
The Appellate Division reversed and remanded the case because Defendant was not adequately advised of the consequences of proceeding without counsel.
The Court found that although due process did not require the appointment of counsel for indigent defendants in a Domestic Violence proceeding who were opposing a request for an FRO, fundamental fairness required that a Defendant understood that he or she had a right to retain legal counsel, and that a Defendant was afforded a reasonable opportunity to retain an attorney.