In a Decision – C.C. v. J.A.H., (a “Reported Decision") >> the Court Held:
The Appellate Division determined that the fact that the parties only exchanged text messages was sufficient to constitute a Dating Relationship.
After plaintiff texted defendant to declare that she had no romantic interest in him, defendant began sending plaintiff a series of vulgar, insulting, and threatening messages, including threatening to have plaintiff fired and to file a civil lawsuit against defendant.
The definition of a "[v]ictim of domestic violence" includes "any person who has been subjected to domestic violence by a person with whom the victim has had a dating relationship."
The Appellate Division affirmed the entry of the FRO, agreeing with the trial court that the parties had a dating relationship under the Prevention of Domestic Violence Act, noting that the parties regularly engaged in intimate communications, often involving sexually explicit messages. The court held that parties could still establish an intimate relationship without having an in-person date.