Roberts v. Roberts, 19 A.3d 277

Husband and Wife married August 12, 1989; they have a 14-year-old adopted daughter.
They separated around April 1, 2008; cross-consent PFAs were entered restricting contact in May 2008.
Husband filed for divorce January 16, 2009; a prior decree was vacated due to timeliness concerns.
Husband completed an April 2009 PEP (basic course) that did not include a DV component; Wife had not filed a Certificate of Completion as of December 11, 2009.
Family Court Commissioner granted the divorce after noting the PEP issue and finding potential, but not necessary, linkage to DV education; August 2009 Wife Certificate still not filed.
Court ultimately affirmed the divorce decree, holding that 1507(h) did not require a pre-decree DV-Pep completion and that Husband’s April 2009 PEP sufficed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 1507(h) requires a DV-component PEP.	Wife: DV history mandates DV PEP for Husband.	Husband: no demonstrable DV history; no DV PEP required.	No demonstrable DV history; April 2009 PEP sufficed.
Whether completing a PEP is a condition precedent to entry of the divorce decree.	Wife: PEP completion must occur before decree.	Husband: PEP completion not required before decree; waiver possible.	PEP completion is not a strict condition precedent to entry of a divorce decree.
Whether the court erred in not requiring pre-decree DV-Pep completion despite possible DV history.	Wife contends error in not imposing DV-education.	Husband: not required given no demonstrable DV history.	Court did not err; no demonstrable DV history.

Solis v. Tea, 468 A.2d 1276 (Del. 1983) (standard of review and statutory interpretation guidance referenced by court)
Forrester v. Forrester, 953 A.2d 175 (Del.2008) (properly applying statutory provisions; review standards)
Jones v. Lang, 591 A.2d 185 (Del.1991) (abuse of discretion and standard of review principles)
Villarroel v. Villarroel, 562 A.2d 1180 (Del.1989) (family court jurisdiction and ancillary proceedings)