People v. Allen

Defendant was convicted of domestic battery. Victim testified that she and Defendant had dated off an on for about 8 months; Defendant testified that the relationship was primarily sexual, and not "romantic". For domestic battery conviction, to show that victim was a "family or household member", which includes persons in a dating or engagement relationship, State must prove that relationship was a "serious courtship"; at a minimum, an established relationship with a significant romantic focus.  "Romantic" is interpreted broadly to include relationships that are romantic in a conventional sense and those that are mainly sexual. (McLAREN and BRIDGES, concurring.)