To the Editor:

Recently, the Appellate Division considered whether there is a right to appointed counsel for either a plaintiff or defendant in domestic violence matters. In D.N. v. K. M. (Docket Nos. A-3201-11T3 and A-3022-11T3), the New Jersey Appellate Division reaffirmed that there is no entitlement to counsel for parties in a civil restraining order proceeding holding that an "entry of a domestic violence FRO … does not result in a ‘consequence of sufficient magnitude’ to warrant the mandatory appointment of counsel" and that "the Legislature did not intend to invoke the power of the State to prosecute civil requests for restraining orders."