Where, as here, the nature of the parties' relationship is the pivotal prerequisite to acquiring jurisdiction under the Act, the trial judge should consider the factors identified in Andrews v. Rutherford, 363 N.J. Super. 252, 260, 832 A.2d 379 (Ch. Div. 2003), as adopted by our court in S.K. v. J.H., 426 N.J. Super. 230, 235, 43 A.3d 1248 (App. Div. 2012). Those factors are:

While the J.S. court declined to endorse the Andrews test, a subsequent appellate decision has done so. In S.K. v. J.H., 426 N.J. Super. 230, 236, 43 A.3d 1248 (App. Div. 2012), the Appellate Division concluded "that Andrews poses the appropriate questions to be considered when the existence of a dating relationship is disputed while recognizing that, if applicable, other factors unique to the parties should also be weighed." There, the plaintiff and the defendant were on a trip abroad with dozens of others.

In S.K. v. J.H., 426 N.J.Super. 230 (App. Div. 2012), we suggested consideration of the following questions to determine whether there is a dating relationship sufficient to grant relief under the PDVA: 1. Was there a minimal social interpersonal bonding of the parties over and above a mere casual fraternization?

Where, as here, the nature of the parties' relationship is a prerequisite to jurisdiction under the PDVA, the trial judge should consider the factors identified in Andrews v. Rutherford, 363 N.J.Super. 252, 260 (Ch. Div. 2003), as adopted by this court in S.K. v. J.H., 426 N.J.Super. 230, 235 (App. Div. 2012). Those factors are:

"We accord substantial deference to Family Part judges, who routinely hear domestic violence cases and are 'specially trained to detect the difference between domestic violence and more ordinary differences that arise between couples.'" Ibid. (quoting J.D. v. M.D.F., 207 N.J. 458, 482 (2011)); see also S.K. v. J.H., 426 N.J.Super. 230, 238 (App. Div. 2012). Consequently, findings by a court "are binding on appeal when supported by adequate, substantial, credible evidence."

"We accord substantial deference to the Family Part judges, who routinely hear domestic violence cases and are 'specially trained to detect the difference between domestic violence and more ordinary differences that arise between couples.'" Ibid. (quoting J.D. v. M.D.F., 207 N.J. 458, 482 (2011)); see also S.K. v. J.H., 426 N.J.Super. 230, 238 (App. Div. 2012). Consequently, findings by a court "are binding on appeal when supported by adequate, substantial, credible evidence." T.M.S. v. W.C.P., 450 N.J.Super. 499, 502 (App. Div. 2017) (quoting Cesare v. Cesare,

Ibid. (quoting J.D. v. M.D.F., 207 N.J. 458, 482 (2011)); see also S.K. v. J.H., 426 N.J.Super. 230, 238 (App. Div. 2012). The appellate court may review the FRO record to determine whether the record as a whole supports issuance of the FRO.

Ibid. (quoting J.D. v. M.D.F., 207 N.J. 458, 482 (2011)); see also S.K. v. J.H., 426 N.J.Super. 230, 238 (App. Div. 2012). Findings by a trial court "are binding on appeal when supported by adequate, substantial, credible evidence." T.M.S. v. W.C.P., 450 N.J.Super. 499, 502 (App. Div. 2017) (quoting Cesare v. Cesare, 154 N.J. 394, 411-12 (1998)). Stated another way, we do not disturb a court's findings unless those findings are "so manifestly unsupported by or inconsistent with the competent, relevant and reasonably credible evidence as to offend the interests of justice."

"We accord substantial deference to Family Part judges, who routinely hear domestic violence cases and are ‘specially trained to detect the difference between domestic violence and more ordinary differences that arise between couples.’ " Ibid. (quoting J.D. v. M.D.F., 207 N.J. 458, 482, 25 A.3d 1045 (2011)); see also S.K. v. J.H., 426 N.J. Super. 230, 238, 43 A.3d 1248 (App. Div. 2012). Consequently, findings by a court "are binding on appeal when supported by adequate, substantial, credible evidence."

Peterson v. Peterson, 374 N.J.Super. 116, 121 (App. Div. 2005) (quoting Cesare v. Cesare, 154 N.J. 394, 411-12 (1998)). "This deferential standard is even more appropriate 'when the evidence is largely testimonial and involves questions of credibility.'" L.M.F. v. J.A.F., Jr., 421 N.J.Super. 523, 533 (App. Div. 2011) (quoting In re Return of Weapons to J.W.D., 149 N.J. 108, 117 (1997)). "We accord substantial deference to Family Part judges, who routinely hear domestic violence cases and are 'specially trained to detect the difference between domestic violence and more ordinary differences that arise between couples.'" C.C., 463 N.J.Super. at 428 (App. Div. 2020) (quoting J.D. v. M.D.F., 207 N.J. 458, 482 (2011)); see also S.K. v. J.H., 426 N.J.Super. 230, 238 (App. Div. 2012). However, we review conclusions of law de novo.