Trials held under the New Jersey Prevention of Domestic Violence Act (PDVA) are some of the most contentious in the Courthouse. The consequences of being found guilty of domestic violence are serious and the violation of a Final Restraining Order (FRO) will trigger arrest and institution of criminal proceedings. Despite such potential results, New Jersey courts have consistently held that a party in a domestic violence case does not have the right to appointed counsel if he or she cannot afford to retain a lawyer and that the court has no obligation to inform the party that he or she has the right to an attorney. The premise for this position is that unlike the criminal statutes, which are punitive in nature, the PDVA is designed to “remediate behavior”. This distinction was recently addressed in A.M v. M.M. (names redacted by the court) decided by the Appellate Division on June 16, 2014. In this case, M.M. challenged the issuance of an FRO against him based on the court’s alleged failure to advise him of his right to counsel and its further alleged failure to determine whether he voluntarily waived his right to assistance of counsel. The appellate court affirmed the trial judge’s rulings on the premise described above. The take-away is that no matter how serious the consequences of an FRO for the defendant (or the consequences of the denial of an FRO for the victim), neither party should expect a change in New Jersey law in the foreseeable future.