In a Decision – A.R. v. J.M., (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that the acts of violence by Father to Mother, and the facts of the case, demonstrate that the finding of Domestic violence was axiomatic or perfunctory and self-evident.
The Appellate Division found that Mother established the need for an FRO as a matter of law. The Appellate Division reached this conclusion based on Father's commission of a predicate act that involved physical violence against Mother; the evidence demonstrating a previous history of violence between the parties, and the fact that, under the circumstances, the issuance of final restraints is undoubtedly in Mother's best interests.