In a case of first impression in New Jersey, an appeals court affirmed a trial court’s ruling that a paid escort qualifies as a "date”, and thus is a victim under the New Jersey Prevention of Domestic Violence Act. In J.S. v. J.F., the trial judge determined that the parties had entered into a "dating relationship" even though most of their "dates" were at the club where J.S. danced. As for the exchange of money involved, J.S. testified that J.F. was simply trying  to help her out financially, as opposed to rendering payment for professional services, an argument unsuccessfully advanced by J.F.’s counsel.

By way of background, J.S. sought protection under the Domestic Violence Act when she began "seeing another man" to which J.F. responded by sending her harassing and threatening text messages. The case serves as fair warning that the commonly-held definition of "dating" is being expanded to satisfy the presumed legislative intent of the Act. As we lawyers like to say, "please be guided accordingly". As others might put it, "buyer beware".