As the trial court has failed to do so, we reverse. In so ruling, we find In re Marriage of McCoy, 253 Ill. App.3d 958 (1993), Glater v. Fabianich, 252 Ill. App.3d 372 (1993), and In re Marriage of Hagaman, 123 Ill App.3d 549 (1984), distinguishable from the case at bar. In McCoy, the plenary order at issue included a provision which stated that the court had considered all the relevant statutory factors.

Other factors that may be considered are: the nature of the living arrangements, whether the parties had any other living accommodations; whether they kept personal items at the shared residence; and whether the parties shared in the privileges and duties of a common residence, such as contributing to household expenses or helping with maintenance. See In re Alexis H., 401 Ill. App. 3d 543 (2010); Glater v. Fabianich, 252 Ill. App. 3d 372 (1993). We agree that the statute is not so broad that it includes situations, as in Young, where the defendant and victim had no real connection other than that they slept under the same roof on a few occasions.

To place the details of respondent's argument in context, it is necessary to review the relevant provisions of the applicable statute, the Domestic Violence Act (750 ILCS 60/101 et seq. (West 2018)). ¶ 38 The Domestic Violence Act is to be liberally construed and applied to advance its underlying purposes, which include "to promote safe and healthy families" by "prevent[ing] abuse and harassment between family or household members." 750 ILCS 60/102 (West 2018); People v. Leezer, 387 Ill. App. 3d 446, 449-50 (2008); Glater v. Fabianich, 252 Ill. App. 3d 372, 375 (1993). The standard of proof in a proceeding to obtain an order of protection is proof by a preponderance of the evidence.

¶ 162 The Domestic Violence Act is to be liberally construed and applied to advance its underlying purposes, which include "to promote safe and healthy families" by "prevent[ing] abuse and harassment between family or household members." 750 ILCS 60/102 (West 2016); People v. Leezer, 387 Ill. App. 3d 446, 449-50 (2008); Glater v. Fabianich, 252 Ill. App. 3d 372, 375 (1993). The Domestic Violence Act provides for three types of orders of protection—emergency (750 ILCS 60/217 (West 2016)), interim (750 ILCS 60/218 (West 2016)), and plenary (750 ILCS 60/219 (West 2016))—as well as various types of remedies (750 ILCS 60/214 (West 2016)).

We note that this definition is, in all pertinent respects, identical to the definition found in the Illinois Domestic Violence Act of 1986(DVA) (750 ILCS 60/103 (West 2010) ), which was designed “to prevent abuse between persons sharing intimate relationships.” Glater v. Fabianich, 252 Ill.App.3d 372, 376, 192 Ill.Dec. 136, 625 N.E.2d 96 (1993) ; see also 750 ILCS 60/102 (West 2010) (requiring that the DVA be liberally construed to support victims' efforts to avoid further abuse, to clarify law enforcement's responsibilities, to expand remedies, to recognize that domestic violence is a serious crime and to recognize the legal system's past ineffectiveness). The jury instruction defining family or household members omitted the language specifying that ordinary fraternization does not constitute a dating relationship.

Also, the sentence regarding high-risk adults expands, not restricts, the scope of the definition of "family or household members." We need not engage in an exploration of the "concepts of guest, occupant, tenant, and visitor," as is urged by Miller, where, as here, the statute is clear. ¶ 22 Furthermore, the cases cited by respondent are inapposite. Miller cites Glater v. Fabianich, 252 Ill. App. 3d 372 (1993) for the proposition that the IDVA applies to "relationships by marriage and blood and to lesser but intimate relationships." The respondent in Glater argued that he did not formerly share a common dwelling with the petitioner.

We find that "[t]he General Assembly intended the domestic violence provisions to address the particular problems of abuse in intimate relationships." People v. Young, 362 Ill. App. 3d 843, 850 (2005), citing People v. Whitfield, 147 Ill. App. 3d 675, 679 (1986); see also Alison C, 343 Ill. App. 3d at 652, citing Glater v. Fabianich, 252 Ill. App. 3d 372, 376 (1993). We also find that "it is clear that a `serious courtship' must be, at a minimum, an established relationship with a significant romantic focus."

We find that "[t]he General Assembly intended the domestic violence provisions to address the particular problems of abuse in intimate relationships." People v. Young, 362 Ill. App. 3d 843, 850 (2005), citing People v. Whitfield, 147 Ill. App. 3d 675, 679 (1986); see also Alison C., 343 Ill. App. 3d at 652, citing Glater v. Fabianich, 252 Ill. App. 3d 372, 376 (1993). We also find that "it is clear that a `serious courtship' must be, at a minimum, an established relationship with a significant romantic focus."

720 ILCS 5/2-6(b) (West 2002). We recognize that Glater v. Fabianich, 252 Ill. App. 3d 372, 375-76 (1993), provides some support for the proposition that two people can "share a common dwelling" if one stays briefly with the other, at least if they share household expenses. The portions of Glater that support this proposition are dicta and without supporting reasoning.

We believe that it would be unfair here to resolve any doubts arising from the incomplete record against respondent. See Glater v. Fabianich, 252 Ill. App. 3d 372, 377 (1993). The record reveals that respondent attempted, apparently unsuccessfully, to obtain the missing transcript from the circuit court clerk. Respondent was not present during the hearing and therefore would not have had a meaningful opportunity to present a bystander's report or an agreed statement of facts.