In a Decision – B.P. v. R.P., , (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that the trial court’s failure to inform Defendant of the consequences of a Final Restraining Order and his right to retain counsel were a violation Due Process.
The consequences of a FRO included fingerprinting and listing in a registry, with violation of the order constituting a contempt offense that required imprisonment. Thus, the court ruled that defendants in domestic violence complaints were entitled to due process that included the right to seek counsel. Although the court acknowledged that indigent defendants were not entitled to appointed counsel, it held that fundamental fairness required ensuring that a defendant understood he or she had the right to obtain counsel and providing the opportunity for defendant to obtain counsel if he or she wished.