Overall the Supreme Court of New Jersey had another busy year, but not in the area of family law. The matrimonial bar was treated to only two significant decisions, neither of which was particularly earth shattering, one on the constitutionality of the Prevention of Domestic Violence Act, and the other on distribution of assets after the death of a party to a divorce action. In both cases, the Court released per curium decisions, looking to public policy and equitable considerations in reaching their determinations.
In Crespo v. Crespo , 201 N.J. 207 (2010), the Court declared the Prevention of Domestic Violence Act to be constitutional based substantially on the reasons expressed by Judge Fisher in the Appellate Division. See Crespo v. Crespo , 408 N.J.Super. 25 (App. Div. 2009).
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