On Dec. 24, 2018, for jurisdictional purposes, Judge Mitchell I. Steinhart interpreted the Domestic Violence Act’s phrase “member of the household” to include a nanny hired to care for the victim’s children. E.S. v. C.D., 460 N. J. Super. 326 (Ch. Div. 2018).

Defendant had been employed by plaintiff, as a live-in nanny, for approximately seven months. For weeks after being fired, as a result of defendant’s assaulting plaintiff’s child, defendant made numerous harassing telephone calls and sent threatening texts to plaintiff.