This domestic violence case concerns the breadth of “household member” jurisdiction in the context of a modern, blended-family where the parties are adult, half-siblings who shared meaningful, regular parenting time with their common father during their youth – though never resided together. Throughout their youth, the parties regularly and consistently spent substantial periods of time at their common father’s home, including the defendant spending overnights every other weekend during the school year and more extended times during the summer at their father’s home. Although he did not have a bedroom, he had a fixed sleeping arrangement and drawers containing underwear, gym shorts, and toiletries. During and after college, their in-person contact decreased, but they still gathered informally and at family milestones and vacations.
In view of those facts, for purposes of the Prevention of Domestic Violence Act’s (“PDVA”) jurisdictional “household member” requirement, the court holds that a child whose parents are separated during youth but who spends meaningful, regular periods of time at a parent of alternate residence’s home such that he or she is substantially integrated into that household may have two “households” creating jurisdiction vis-à-vis a victimized half-sibling who resided solely with the common parent. “Household member” as used in the PDVA’s definition of “victim of domestic violence” must be sufficiently flexible to accommodate the ever-changing dynamics of modern families. To restrict a child whose parents are separated to only one household despite meaningful, regular time in a second household would untenably alter the statutory construct, discriminate against members of blended families, and unduly restrict the broadly designed, legislatively crafted protections afforded victims of domestic violence.