New Jersey Division of Child Protection and Permanency v. Y.A. in the Matter of R.A., I.A., S.A., and Y.A., 101 A.3d 23

Division sought to prove sexual abuse of RA by her father Y.A. at a fact-finding hearing; RA testified in camera detailing three incidents between 2008–2009, including touching and underwear removal.
RA provided credible, emotionally harrowing testimony; the trial judge found her credible and in tears during testimony.
Dates of incidents were not precisely remembered, but the judge credited the overall credibility and found abuse proved by a preponderance of the evidence.
The court addressed whether RA’s in-camera, uncorroborated testimony could support a finding of abuse under N.J.S.A. 9:6-8.21 to -8.73 (Title 9) and whether corroboration was required.
N.J.S.A. 9:6-8.46(a)(4) allows prior statements by a child to be used but requires corroboration if the child does not testify; here, RA testified in camera and was cross-examined, leading to appellate review of credibility and sufficiency.
The matter culminates in an affirmation of the Family Part’s finding that Y.A. abused RA and rejection of the corroboration requirement when the child testifies in person.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether N.J.S.A. 9:6-8.46(a)(4) requires corroboration of in-camera child testimony.	RA's testimony in camera is sufficient evidence without independent corroboration.	Corroboration is required under 9:6-8.46(a)(4) when the child testifies in camera.	Corroboration not required when child testifies in court.
Whether the trial court’s finding of abuse was supported by substantial credible evidence.	Credible testimony established abuse by preponderance.	Lack of precise dates undermines credibility.	Evidence substantial and credible; abuse proven.
Whether the trial court abused its discretion in relying on in-camera testimony without corroboration.	In-camera testimony alone suffices when credible.	Need for corroboration undermines proof.	No abuse of discretion; corroboration not required in this context; affirmed.

Cesare v. Cesare, 154 N.J. 394 (1998) (standard for appellate deference to family court credibility findings)
N.J. Div. of Youth & Family Servs. v. I.Y.A., 400 N.J. Super. 77 (App. Div. 2008) (deference to factual findings in abuse/neglect cases)
N.J. Div. of Youth & Family Servs. v. M.C. III, 201 N.J. 328 (2009) (special deference to family court credibility and factual findings)
N.J. Div. of Youth & Family Servs. v. F.M., 211 N.J. 420 (2012) (preponderance standard for abuse/neglect findings)
L.A., 357 N.J. Super. 155 (App. Div. 2003) (corroboration of out-of-court statements allowed via other evidence)
Z.P.R., 351 N.J. Super. 427 (App. Div. 2002) (corroboration principle for child statements in abuse cases)
Pascale v. Pascale, 113 N.J. 20 (1998) (trial court credibility determinations receive deference)