Storch v. Sauerhoff
334 N.J. Super. 226, 757 A.2d 836 (2000)
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Rule of Law:
Jurisdiction under the Prevention of Domestic Violence Act can extend to individuals who do not cohabitate if their relationship constitutes a 'de facto household,' which is determined by the qualities and characteristics of the relationship, such as a substantial, integrated family life, close physical proximity, and frequent interaction.
Facts:
- Erika Sauerhoff is the stepmother of Helene Storch and has been married to Storch's father for approximately 30 years.
- Storch last resided in the same household with Sauerhoff and her father in 1981, about 19 years prior to the case.
- For the past 11 years, Storch and Sauerhoff have lived in separate residences on the same block.
- Storch's half-sister, who is Sauerhoff's daughter, owns property adjacent to Storch's home, and their children often play together on a common lot which Sauerhoff frequently visits.
- Sauerhoff and her husband contributed over $125,000 toward the purchase of Storch's home and the adoption of her children.
- Sauerhoff occasionally cares for Storch's children, and Storch attends various family and religious functions at Sauerhoff's home.
Procedural Posture:
- Helene Storch filed a complaint seeking a Final Restraining Order against Erika Sauerhoff in the Superior Court of New Jersey, Chancery Division, Family Part.
- The court granted Storch a Temporary Restraining Order based on the parties' status as former household members.
- At the final hearing, Sauerhoff moved to dismiss the complaint, arguing the court lacked jurisdiction.
- The court entered an Amended Temporary Restraining Order and requested legal briefs from both parties on the issue of jurisdiction before proceeding to a final hearing.
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Issue:
Does a relationship between a stepmother and an adult stepdaughter, who have not lived in the same residence for 19 years but live on the same block, share deep familial and financial ties, and interact frequently, constitute a 'household member' relationship sufficient to establish jurisdiction under New Jersey's Prevention of Domestic Violence Act?
Opinions:
Majority - Alcazar, J.S.C.
Yes. Jurisdiction exists because the parties' relationship constitutes a de facto household membership under the Prevention of Domestic Violence Act. The term 'household member' is not defined by the physical sharing of a single roof but must be interpreted broadly and flexibly in light of the Act's remedial purpose to protect victims. The court found that the parties' long-standing familial relationship, close living proximity for over a decade, financial entanglement, and frequent, unavoidable interactions around their children created a 'substantial integrated family relationship.' This relationship, born out of their former domestic arrangement, places the plaintiff in a position of susceptibility to the type of abusive and controlling behavior the Act is designed to prevent, making them 'household members' for jurisdictional purposes despite their separate residences.
Analysis:
This decision significantly broadens the jurisdictional reach of New Jersey's Prevention of Domestic Violence Act by establishing the 'de facto household member' concept. It moves the analysis away from a rigid requirement of cohabitation towards a flexible, fact-sensitive inquiry into the nature and quality of the relationship. This precedent allows courts to protect individuals in complex, non-traditional family structures where deep entanglement and close proximity create the potential for domestic abuse, even without a shared address. Future cases will now look to the totality of the circumstances, including financial ties and frequency of contact, to determine if a relationship is sufficiently 'family-like' to warrant protection under the Act.
