In an important case of first impression, a Superior Court judge entered a protective order against domestic violence by the defendant, further "expressly providing that plaintiff’s unborn child shall, upon birth, be automatically deemed an additional protected person." B.C. v. T.G., No. FV-15-1033-13 (Chancery Division, Ocean County, Jan. 31, 2013) [emphasis added].

Judge Lawrence Jones found the 18-year-old defendant had organized a group of people to beat up his 17-year-old girlfriend after she told him she was pregnant. She sustained significant injuries and at the time of the hearing on the restraining order, it was unclear whether the fetus had been injured. Jones found that there was a substantial continuing risk of violence to the plaintiff, as well as to her unborn child and, interpreting the Prevention of Domestic Violence Act liberally, decided he had the authority to include the plaintiff’s unborn child within the restraining order, to be automatically added as a "protected person" upon the child’s birth.