In a Decision – J.H. v. C.H., (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that the Trial Court properly determined that the issues between the parties were volatile and their relationship was ongoing. The pending criminal matter – along with the fact that defendant continued to reside with plaintiff's mother – underscored those findings and the judge's determination that plaintiff feared defendant "might take further action against him." Seeking a change in his niece's attitude apparently was borne of Uncle's fear of recurrence.