In D.M.R. v. M.K.G., the New Jersey Appellate Division reviewed an order granting a final restraining order (FRO). The FRO was issued during the pandemic after both parties appeared pro se at the Zoom hearing. The Appellate Division reversed and remanded. Though the Court went to great lengths to concede how difficult pro se FRO hearings are via Zoom, the Court found it improper to proceed only 24 hours after the defendant received a copy of the TRO. Also, the trial court’s questioning of a witness went too far towards advocacy and not simply clarifying the record.
