C.C. v. J.A.H.

Plaintiff was granted a temporary restraining order and, after a contested hearing, was awarded a final restraining order. At issue was whether plaintiff could establish a “dating relationship” as a necessary element in receiving the FRO. The parties met at a gym, where the plaintiff worked and the defendant regularly exercised. They never went on a date, never held hands, never kissed, never met one another’s friends. But they did exchange more than 1300 — often sexually explicit — text messages. The Appellate Division agreed with the trial court that these electronic communications amounted to a dating relationship.

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