Is Coercive Control Recognized in New Jersey?

What actually got enacted: N.J.S.A. 2C:25-29(a)(7)

The provision that became law amends Section 13 of the Prevention of Domestic Violence Act of 1991 (N.J.S.A. 2C:25-29) — the statute governing what a court considers when deciding whether to issue a final restraining order after a predicate act has been shown. A1475 added a new factor, (a)(7), to the list the court “shall consider but not be limited to”: “[a]ny pattern of coercive control against a person that in purpose or effect unreasonably interferes with, threatens, or exploits a person's liberty, freedom, bodily integrity, or human rights.” The statute directs the court to specifically consider evidence of the need for protection from immediate danger or the prevention of further abuse, and requires written findings if the court treats some coercive-control factors as more or less relevant than others.

The same section lists non-exclusive examples of coercive control: isolating someone from friends, relatives, transportation, medical care, or other sources of support; depriving someone of basic necessities; monitoring a person's movements, communications, daily behavior, finances, economic resources, or access to services; compelling someone by force, threat, or intimidation — including threats based on actual or suspected immigration status; threatening to make or making baseless reports to police, courts, the Division of Child Protection and Permanency (DCPP), the Board of Social Services, or Immigration and Customs Enforcement (ICE); threatening to harm or kill a relative or pet; threatening to deny or interfere with custody or parenting time other than through enforcement of a valid order; or any other factor the court deems relevant or material.

A second, smaller change: what a plaintiff can put on the complaint form

A1475 also amended Section 12 of the 1991 act (N.J.S.A. 2C:25-28), adding a new provision letting a plaintiff filing a domestic violence complaint include information about coercive control — using the same definition and the same list of examples — on the initial complaint form itself. This doesn't change what has to be proven; it just gives a plaintiff an explicit, named place to raise the issue from the outset rather than only at the restraining-order hearing.

A 2026 appellate opinion confirms exactly how this works in practice

In S.M.T. v. S.A., decided February 10, 2026 and approved for publication, New Jersey's Appellate Division addressed this directly. The court explained: “Effective January 8, 2024, the PDVA was amended to include coercive control among the statutory factors courts must consider when determining whether to issue an FRO. N.J.S.A. 2C:25-29(a)(7). Coercive control is not among the predicate acts enumerated in the PDVA; rather, it is analyzed pursuant to the secondary analysis of Silver once a predicate act of domestic violence has been proven.” In that case, the trial court had found the husband committed simple assault — a predicate act — but failed to make findings on the wife's coercive-control allegations (limiting her travel, controlling family finances, surveillance by electronic means, and sleep deprivation among them) when deciding whether a restraining order was necessary. The Appellate Division held that failure was reversible error and remanded for entry of a final restraining order, with the coercive-control evidence folded into that second-step analysis.