Appellate Victory: Hand & Toker Family Law Successfully Defends Final Protective Order Under New Jersey SASPA/VASPA

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Appellate Victory: Hand & Toker Family Law Successfully Defends Final Protective Order Under New Jersey SASPA/VASPA

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October 22, 2025—Princeton, New Jersey


Hand & Toker Family Law, LLC
 is proud to announce an appellate victory in M.K. v. B.L. (A-1849-23), in which the New Jersey Appellate Division upheld a Final Protective Order (FPO) issued under the Sexual Assault Survivor Protection Act (SASPA)—now known as the Victim’s Assistance and Survivor Protection Act (VASPA).

Our firm represented the plaintiff-respondent, a Princeton University student who sought protection following a 2023 campus incident involving nonconsensual sexual contact and strangulation. After a full evidentiary hearing, the Family Part found the conduct to be nonconsensual and entered a protective order to safeguard our client’s safety and well-being.

The defendant appealed, but the Appellate Division affirmed the trial court’s decision, holding that:

  • New Jersey’s affirmative consent standard governs all determinations of voluntary sexual contact;
  • A survivor’s credible testimony and emotional trauma can meet the statutory requirement of showing a “possibility of future risk” to safety or well-being; and
  • Courts have broad discretion to craft tailored, campus-specific restrictions to ensure a survivor’s continued protection.

This decision reinforces the strong intent behind SASPA/VASPA—to provide accessible, lasting protections for survivors of sexual assault, recognizing that emotional and psychological safety are as vital as physical security.

Hand & Toker Family Law is honored to have defended this important ruling and to continue our mission of protecting and empowering survivors across New Jersey.

Dedicated to protecting what matters most.

Read the full opinion here.