Sz v. Mc, 11 A.3d 404

Plaintiff S.Z. sues under the Prevention of Domestic Violence Act alleging harassment and stalking by M.C.
M.C. resided in plaintiff's home with plaintiff, plaintiff's wife, and three children for seven months (Oct 2008–Apr 2009).
Plaintiff testified to two incidents of M.C. spying on him from a ladder outside the bathroom window and a later incident of privacy invasion; he told M.C. he was not gay.
Plaintiff discovered a hidden audio-video camera placed in his truck by M.C. during Super Bowl weekend 2010 and viewed the footage.
Trial court sua sponte raised jurisdiction, ruling a household member requires permanent status and not a transient guest.
Appellate Division reversed, holding the Act covers non-traditional household members and remanded for merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a seven-month co-residential non-romantic male is a household member under the Act	S.Z. contends M.C. was a household member under N.J.S.A. 2C:25-19(d).	M.C. argues household member requires permanent familial/romantic ties, not a temporary guest.	Yes; jurisdiction exists; M.C. qualifies as household member.
Whether the trial court had jurisdiction to address harassment and stalking claims	Act provides protection for a broad range of intimate or household relationships.	Act limits jurisdiction to traditional or permanent household relationships.	Jurisdiction exists; the Act applies to this relationship.

Hamilton v. Ali, 350 N.J. Super. 479 (Ch.Div. 2001) (dormitory suitemate held as household member; broadened category)
Bryant v. Burnett, 264 N.J. Super. 222 (App.Div. 1993) (cohabitation not required; three-month living together suffices for household member)
Jutchenko v. Jutchenko, 283 N.J. Super. 17 (App.Div. 1995) (brothers not cohabiting for years not covered by Act)
Smith v. Moore, 298 N.J. Super. 121 (App.Div. 1997) (harassment between unrelated women not within Act when not linked to living arrangements)