D.N. v. K.M., C-808 September Term 2012; Supreme Court; per curiam opinion; dissent by Albin, J.; decided January 13, 2014. [Sat below: Judges Lihotz, Ostrer and Kennedy in the Appellate Division; Judge Bell in the Law Division.] DDS No. 20-1-xxxx [13 pp.]
D.N. v. K.M., 429 N.J. Super. 592 (App. Div. 2013), held that due process does not require the appointment of counsel for indigents presenting or defending a private party’s civil action under the Prevention of Domestic Violence Act, N.J.S.A. 2C:25-17 to -35. D.N. filed a petition for certification.