Immigration, domestic violence, and what the family practitioner should know.

Florida's warm climate and beautiful beaches lure many people outside the state to adopt Florida as home. For noncitizens, the attraction is much deeper than aesthetics. It is the hope to find the American dream and to gain freedoms not afforded in other countries. According to the United Nations Human Development Report 2004, Miami has the largest percentage of noncitizens of any city in the world. (1) Therefore, no matter what area of the law in which the Florida lawyer engages, immigration law will overlap in some way. This article is designed to take the Florida lawyer through some of the essentials necessary in representing noncitizens in the context of family law: more specifically, special considerations of immigrant victims of domestic abuse, the impact of state court in civil and criminal actions, federal remedies, and practical considerations for the family law attorney.

Victims of domestic violence face many challenges in escaping their abusers. Being battered coupled with a less than favorable immigration status, further builds a barrier in the mind of the abused. (2) Immigration status may be used as a control device by the abuser in order to pressure the abused partner to remain in a violent relationship. (3) Cultural barriers are also significant since different nations accept domestic violence as the norm in the family, or have limited legal and social programs compared to those available in the United States. (4) Some immigrant victims have the misconception that legal protections afforded in the United States do not apply to them, or they become frustrated in asking for assistance for shelter, financial aid, food, and legal remedies due to their inability to speak English. (5) Underlying all of these fears is the concern that the legal system will deport them or the abuser, their only means for support. (6)

There are sources of information that the Florida practitioner can use to aid the client with these issues. For example, the Florida Coalition Against Domestic Violence (FCADV) is the umbrella organization for all of the certified domestic violence shelters in Florida. Whether your client is from a giant urban area such as Miami, or a rural community such as Macclenney, FCADV can provide direction for which services are available in your client's community. Several advocacy groups specifically serve the immigrant community. The Florida Immigrant Advocacy Center is a full-service, statewide legal services organization that not only provides a lawyer for the battered immigrant, but also has established relationships with other community service agencies throughout Florida. The Haitian Refugee Domestic Violence Project provides services to the Haitian--Creole community in Dade, Broward, and Palm Beach counties, (7) including translation services, injunction assistance, referrals, safety planning, and education programs. Other organizations, such as World Relief, Lutheran Social Services, and Catholic Charities, also assist noncitizen victims of domestic abuse.

Civil Remedies Available to Noncitizen Victims of Domestic Violence

There are civil remedies available to an abused spouse or intimate partner, such as filing an application for an injunction for protection against domestic violence or repeat violence. In addition to the "stay away" injunctive relief, the victim may ask the court for ancillary relief such as temporary use of the residence, child custody, child support, and spousal support. (8) The batterer may also be ordered to undergo psychological evaluations, submit to drug and alcohol evaluation/ treatment, and complete a batterer's intervention program (BIP). (9) Child visitation and/or visitation exchange may be supervised by a certified supervised visitation center or by a third party. At each step of the process, the noncitizen victim may be frustrated and intimidated by language barriers, cultural norms from her country of origin, and fear of retribution from her abuser. It is imperative for the family practitioner to be sensitive to these barriers and be willing to provide the additional support needed to make the process less daunting.

There is no minimum residency requirement to apply for a civil order of protection or injunction. Any person who is the victim of domestic violence within Florida (whether they are visiting or are residents) may petition for an injunction for protection against domestic violence. (10) Under F.S. [section] 741.30(j), a victim can apply for a domestic violence injunction in the circuit where the petitioner resides (even if temporary), where the respondent resides, or where the domestic violence occurred. Once the injunction is in place, there is statutory relief to assist the victim should the batterer violate an injunction no matter where the violation takes place.

The immigrant victim that moves or travels from one U.S. jurisdiction with a protective order to Florida is also protected under Florida law. According to F.S. [section] 741.315 (2007), full faith and credit is given to foreign states' protective orders by Florida courts and law enforcement agencies. Most importantly, the orders do not have to be domesticated, and there is no residency requirement in order for them to be enforced. Hernandez v. Ashcroft, 345 F.3d 824 (9th Cir. 2003), broadens the protection even further. Here, the court determined whether calls the victim received while in the United States from her husband, begging her to return to him in Mexico, constituted extreme cruelty even though the violence itself occurred outside the U.S. The court affirmed that it did indeed constitute extreme cruelty under the Violence Against Women Act, (VAWA), and relied heavily upon psychological research data to reach its decision. (11)

If the noncitizen victim of domestic abuse is married to the abuser, either party may contemplate divorce. However, for the noncitizen, divorcing the battering spouse he or she relies on for "status" through family sponsorship may be compromised. Even if a client is undocumented or out of status, they may petition the family court for a divorce if they meet other jurisdictional requirements. Prior to filing a divorce for a noncitizen, the client's legal status should be examined so that the client is able to maintain lawful residency in the United States whether it be by removal of condition, VAWA self-petitioning, U-Visa, or other remedy. A noncitizen victim of abuse is entitled to the same relief as any other party in a Florida dissolution of marriage action such as child custody, visitation, spousal support, equitable distribution of debts/assets, and name change. Throughout the proceedings, the abuser may use threats of deportation, threats of taking and hiding the children, and threats of destroying/confiscating passports and immigration papers as a means of exerting power and control over the victim in lieu of physical violence. In the dissolution action, the practitioner can counter these attempts by putting limits on visitation, building protections into temporary and final orders, and requesting that equitable distribution include the award of all immigration paperwork to the abused spouse.

If the parties are not married, but have a child in common, the non-citizen victim may take advantage of filing for paternity either through a private attorney or the Department of Revenue/Child Support Enforcement without the fear of being reported to federal immigration authorities. It is important paternity is established and that birth records are corrected if the minor child was born in the United States so that the child has proper documentation to seek medical treatment and education. Many times, the minor child will be a United States citizen as a result of being born in the United States even if one or both of the biological parents are noncitizens. If the noncitizen victim of domestic violence is unable or unwilling to secure an injunction for protection against domestic violence, which includes a support award, a request for child support through a paternity action is an effective tool to ensure that your client has the support necessary to care for the minor child once he or she separates from the abusive partner.

State Criminal Law and Noncitizen Abuse

A general perception among noncitizens is that any interaction with the criminal justice system equals deportation. For a victim of crime (including domestic violence), cooperation with law enforcement may assist the victim in securing legal status in the United States. However, the victim may be further endangered by the batterer and/or ostracized by the community for reporting violence to the authorities and cooperating with prosecution. The practitioner needs to be aware of potential threats by the batterer or isolation from the victim's community and be able to provide support for the victim whether through a victim advocate or a loyal support network.

Criminal arrests in Florida also have an effect on noncitizens, especially the accused abuser. The court has an obligation to inquire as to a defendant's citizenship status at the time a plea is entered. (12) If the defendant is not given notice as to the consequences of his/her plea, the defendant's plea can be withdrawn. Pre-approved forms informing noncitizen defendants of their rights have passed appellate scrutiny as long as the court verbally verifies that the defendant intelligently comprehended the written form and the record reflects that the plea was entered knowingly, intelligently, and voluntarily. (13)

How pleas are interpreted for purposes of immigration law can differ dramatically from criminal court. For example, entrance into a drug court or a pretrial intervention/diversion program may result in adjudication of guilt being withheld for purposes of state criminal law. (14) However, federal immigration authorities may still consider this to be a conviction for purposes of extending a visa, adjusting status, or granting citizenship. (15) Whether representing the perpetrator who could face deportation, or the victim, who may lose his or her only source of support, knowledge of how a plea or sentence affects the noncitizen's immigration status is imperative.

One of the foundations of immigration law is that all applicants for lawful status have good moral character, whether it is for lawful permanent residency, a visa, or refugee status. There is no definition of "good moral character" in federal regulations, but rather a list of prohibited activities defining what can bar someone from achieving citizenship. (16) Actual arrests are not the only factors to determine "good moral character." Any evidence of prostitution, drug use, fraud, or domestic violence, even if not reported to the authorities, could hamper an applicant's ability to seek permanent lawful resident status in the United States. Arrests, however minor, may not immediately lead to deportation proceedings, but will ultimately affect the ability of the applicant to achieve lawful status in the United States. (17) Thoroughly questioning your client about prior criminal history and behavior, either in the United States or their country of origin, as well as completing a criminal background check, is necessary before being able to effectively advise your client as to how to proceed in civil, criminal, or immigration proceedings.

The Intersection of Juvenile and Immigration Law

Juvenile courts also provide protection to children with noncitizen parents. Under 8 U.S.C. [section] 1101 (a)(27)(J), a noncitizen juvenile declared dependent can apply for a special immigrant visa and avoid deportation. Requirements for special immigrant juvenile status include, the petitioner must be under 21 years of age and unmarried, declared dependent of a juvenile court, deemed eligible by that court for long-term foster care due to abuse, neglect, or abandonment and a determination in the juvenile proceeding that it would not be in the child's best interest to return to his/her or parent's previous country of nationality. However, the Fourth District held that a state juvenile court lacked subject matter jurisdiction when a minor child from El Salvador entered the country illegally. (18) Even though counsel filed a dependency action on behalf of the minor, the application for special immigration status was denied because the Attorney General did not consent to the trial court's jurisdiction over the dependency proceeding. (19) In 2005, the Florida Rules of Juvenile procedure were amended to include language extending the court's right to retain jurisdiction over the minor until age 21. This gives the Bureau of Citizenship and Immigration Services the opportunity to grant special immigration status to noncitizen juvenile victims of abuse and neglect. (20)

Federal Remedies for Noncitizen Victims of Domestic Violence

There is no federal body of family law. However, immigration law, policies, and procedures are the closest thing to federal family law. (21) The impact of immigration law and policy may be far greater on the Florida family law practitioner than one might think. Recognition for a pathway to lawful status without cooperation from a battering spouse began in 1990 when Congress created the battered spouse waiver to joint petition for removal of conditions on residence. (22) A spouse granted temporary lawful residency by sponsorship of the battering spouse can request that his or her conditional residence be adjusted without the need of her spouse's sponsorship. The spouse must, however, prove that she was married in good faith and was the victim of battery and/or extreme cruelty during the marriage. (23) Other requirements are that the applicant, and battering spouse must have lived together for at least two years, and the application must be filed prior to the expiration of the applicant's conditional residency visa. (24) There are limitations to this relief. A victim of domestic violence is forced to stay in a violent relationship for two years before having the opportunity to file for this relief. Additionally, if the applicant's conditional residency visa expires, he or she is not entitled to relief under this act. If the applicant files the battered spouse waiver application prior to expiration of his or her conditional residence, the conditional residence is extended pending adjudication of her battered spouse waiver application. (25)

The Violence Against Women Act, passed in 1994, was a legislation behemoth that made significant changes in law enforcement, civil remedies for victims of domestic violence, victim's services, and immigration. (26) Since that time, the Violence Against Women Act has been modified, tweaked, and expanded in both 2000 and in 2005. (27) Many of the criticisms and limitations of the battered spouse waiver were addressed by VAWA's creation of the self-petition in 1994. No longer does the battered spouse need to be married and living with her batterer for two years prior to requesting lawful permanent residency status. The VAWA self-petition can be filed on behalf of a battered spouse regardless of her status. However, the battering spouse must be a lawful permanent resident or a United States citizen. (28) If both parties are out of status, VAWA self-petition relief does not apply. The marriage must be in good faith, and the husband and wife must have resided together at some point during the marriage. (29) The applicant must also be able to prove good moral character. (30) The foundation of the self-petition is that the applicant is a victim of battery or extreme cruelty. (31) The definition of "battering" according to federal immigration law is "being the victim of any act or threatened act of violence, including any forceful detention, which results or threatens to result in physical or mental injury." (32) "Extreme cruelty" is defined as "social isolation, threats, economical abuse, other behaviors intended to control and exercise power over spouse/partner." (33) Lawyers for noncitizen victims should be aware that these definitions are far broader and inclusive than definitions of battery and extreme cruelty under Florida criminal law. Also, the proof required to substantiate battery and extreme cruelty are obtained through affidavits, personal records, and photographs that, under Florida law, would be prohibited by the hearsay rule as they are not subject to cross-examination.

Although the self-petition was created within the Violence Against Women Act, relief is available to either gender. The VAWA self-petition is also available to minor children who are victims of abuse, children of the abused spouse, and parents that are abused by their children. With an approved VAWA self-petition, the victim qualifies for all public benefits except Supplemental Security Income (SSI) and food stamps and also gains work authorization so that the victim is no longer reliant on the perpetrator of violence for support. (34)

The Violence Against Women Act also created the "suspension of deportation" or "cancellation of removal" petition for victims of abuse that were subject to deportation and removal when they no longer had lawful status in the United States. The applicant must prove that he or she is a victim of battery or extreme cruelty, must be married to or previously married to a United States citizen or lawful permanent resident, must have good moral character, must reside in the United States continuously for three years, and must show that their removal would cause extreme hardship. (35)

Congress has improved upon the initial VAWA relief with the Victims of Trafficking and Violence Protection Act of 2000. This amendment removed many problems of VAWA and created U-visas for victims of crime. (36) Known as VAWA 2000, this legislation created a nonimmigrant U-visa entitling victims of crimes who are cooperating with law enforcement the ability to petition for a temporary visa. The victim must have suffered "substantial physical or mental abuse" as the result of certain crimes, must possess information concerning the criminal activity and must provide certification from a federal, state, or local law enforcement official, prosecutor, judge, or authority investigation of the criminal activity. U-visa holders are authorized to work, but do not qualify for public benefits. (37) A U-visa holder who has been physically present in the country for four years may apply to be a permanent resident when justified on humanitarian grounds to ensure family unity or when it is otherwise in the public interest unless they have unreasonably refused to cooperate in an investigation or prosecution of criminal activity. (38)

A victim of domestic violence may also qualify for gender-based asylum under federal immigration law if they are unable or unwilling to return to their country of origin or they have a well-founded fear of persecution by the government or a group that the government is unable or unwilling to control. (39) This persecution can be based on race, religion, nationality, political opinion, or particular social group. (40) Gender-based persecution falls within this definition if it can be shown that political opinion or membership in a gender based social group creates the fear of persecution such as allegations of rape, sexual violence, female genital mutilation, coercive family planning practices, and domestic violence. (41)

To allow victims of human trafficking an opportunity to cooperate with law enforcement, T-visas were created under VAWA 2000. A severe form of trafficking in persons is defined as "[s]ex trafficking in which a commercial sex act is induced by force, fraud or coercion, or in which the person induced into said act has not attained 18 years of age," or "the recruitment, harboring, transportation, provision, or obtaining of a person or labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery." (42)

Trafficking takes place in rural cities as well as major metropolitan areas and is often disguised as voluntary prostitution and/or legitimate maid/employment services. Sometimes traffickers portray their victims as family members to feign legitimacy to the outside world. (43) A victim of trafficking may petition for a nonimmigrant T-visa if they can show that they have been a victim of a severe form of trafficking; they are physically present in the United States; and they have complied with any reasonable request for assistance in the investigation or prosecution of a trafficking act or they are under 18 and show that they would suffer extreme hardship involving unusual and severe harm if deported. (44) The visa allows victims access to public benefits and lasts for four years, but the victim may apply for adjustment to permanent residency status after three years. (45)

In 2005, Congress reauthorized relief under VAWA (46) and also created the International Marriage Broker Regulation Act (IMBRA). (47) The push for IMBRA came after two mail-order brides were murdered by their husbands in Washington State. (48) Public policy behind IMBRA necessitated regulation of matchmaking Web sites to reduce the risks of intimate violence. (49) Under the act, U.S. citizens or residents who use international matchmaking organizations are required to provide detailed information to the prospective fiance including information regarding sexual offender registries, criminal background, and number of previous terminated marriages. The matchmaking companies are prohibited from disclosing any information about the prospective foreign fiance until all documentation from the prospective groom is gathered. Additionally, the Department of Homeland Security is required to provide all fiance visa-holders a pamphlet containing information about domestic violence and resources for the noncitizen applicant.

IMBRA also requires all U.S. citizens applying for fiance visas, whether they met through a matchmaking organization, to disclose crimes such as domestic violence, abusive sexual contact, stalking, and criminal offenses related to controlled substances or alcohol. IMBRA also limits the number of applications for fiance visas to two per lifetime and the applications must be more than two years apart. (50) Instead of screening the noncitizen spouse for appropriateness, IMBRA's goal is designed to protect the immigrant spouse from family violence, a shift in policy from previous immigration regulation. (51)

Practical Tips and Considerations on Representing Noncitizen Victims of Violence

A noncitizen can access the civil judicial system without fear of being reported to federal immigration authorities. However, it should be noted that although there is no bar to accessing relief via a state court, the result, whether it be civil or criminal, may impact the noncitizen's immigration status. If you are representing a noncitizen, it is recommended that you consult with an immigration attorney educated in the specific area of family violence who can advise you how your client's involvement in the civil and criminal justice system will affect their immigration status.

Immigrant victims of domestic violence share many of the same experiences of power and control by their abuser such as threats of deportation, physical violence, isolation from family and community, and economic abuse. (52) The family law practitioner must understand the client's reluctance to report incidents of abuse to law enforcement and to seek assistance from social service providers. Language barriers and a misunderstanding of the justice system inhibit a noncitizen victim from utilizing the state courts. The certainty of living with a batterer is preferable to the uncertainty of living alone, unable to speak English and forfeiting financial, community, and family support.

The family law practitioner should be sensitive to the diverse backgrounds of clients and be sensitive to the unique barriers facing noncitizen victims of domestic violence. Having a multicultural and multilingual staff with information about services within the community, especially for noncitizen victims, can provide the necessary support to end the abusive relationship. Representing without judgment includes understanding when the noncitizen victims decide not to access the judicial system. Above all, listen to the client and consider the intricacies of not only the civil and criminal state judicial systems, but also the federal immigration system and how to best navigate your client toward the desired goal: Life without violence as a lawful immigrant in the United States.

This column is submitted on behalf of the Family Law Section, Allyson Hughes, chair, and Susan W. Savard, Laura Davis Smith, and Jeffrey A. Weissman, editors.

(1) Human Development Report Kosovo 2004, The Rise of the Citizen: Challenges and Choices (2004), www.ks.undp.org/repository/ docs/KHDR2004.pdf.

(2) Family Violence Prevention Fund, Immigrant Women: Barriers, www.endabuse. org/programs/display.

(3) Id.

(4) Id.

(5) Id.

(6) NY State Jud. Comm. on Women in Cts., Immigration and Domestic Violence: A Short Guide for New York State Judges, 2004, available at www.courts.state.ny.us/ ip/womeninthecourts/Immigrationand-Domestic Violence.pdf.

(7) Florida Coalition Against Domestic Violence, Immigration and Domestic Violence, www.fcadv.org/projectsimmigration. html

(8) Fla. Stat. [section]741.30(6)(a) (2007)

(9) Id.

(10) See Baumgartner v. Baumgartner, 691 So. 2d 488 (Fla. 2d D.C.A. 1997) (stating that German citizens vacationing in Naples, Florida, were under Florida's jurisdiction for purposes of the wife's petition for injunction for protection against domestic violence).

(11) See amicus brief, Hernandez, 345 F.3d 824 (supporting appellants seeking reversal of decision on review), available at www.nationalimmigrationproject.org/ ImmRightsRes/IRR.html.

(12) Fla. R. CRim. P. 3.172(c)(8).

(13) See Hinds v. State, 726 So. 2d 812 (Fla. 5th D.C.A. 1999) (holding that even though sentencing court did not specifically warn defendant of the danger of deportation, he was not prejudiced by omission because the information was contained in the written plea agreement that defendant testified he had read and understood).

(14) New York City Bar Committee on Criminal Justice Operations, The Immigration Consequences of Deferred Adjudication Programs in New York City (June 2007), available at www.nycbar. org/pdf/report/immigration.pdf.

(15) See I.N.A. [section] 01(a)(48)(A), 8 U.S.C. [section] 101(a)(48)(A).

(16) See I.N.A. [section] 01(f), 8 U.S.C. [section] 1182.

(17) See Chris McGann, One Mistake Robs Man of Citizenship: Moral Character Standard Alleged in Class Action Suit, Seattle PoSt-intelligenCeR, May 10, 2004 (reporting that Kuchil Lee was denied the right to naturalize based on a $154 ticket for picking up too many oysters from a Puget Sound beach. Mr. Lee was part of a class action law suit that settled giving hundreds of applicants denied citizenship the right to naturalize).

(18) P.G. v. DCF, 867 So. 2d 1248 (Fla. 4th D.C.A. 2004).

(19) Id.

(20) Fla. R. Juv. P. 8.415(f)(9).

(21) Kerry Abrams, Immigration Law and the Regulation of Marriage, 91 Minn. L. Rev. 1625 (2007).

(22) 8 U.S.C. [section] 1186A(c)(4)(C) (2000).

(23) Id.

(24) Id.

(25) 8 C.F.R. [section]216.3(a) (2007).

(26) Violence Against Women Act (VAWA) of 1994, I.N.A. [sub section] 204(a)(1)(A) & (B), 8 U.S.C. [sub section] 1154(a)(1)(A) & (B) (2007). I.N.A. [section] 240A(b)(2), 8 U.S.C. [section] 1229b, and former I.N.A. [section] 244(a)(3), 8 U.S.C. [section] 1254(a)(3) (2007).

(27) See Battered Immigrant Women Protection Act of 2000, [sub section] 1501-1513 of the Victims of Trafficking and Violence Protection Act of 2000, Public Law No. 106-386, 114 Stat. 1464, 1518; Violence Against Women Act of 2005, enacted as Public Law No. 109-162, 2006 HR 342(2005).

(28) 8 C.F.R. [section] 204(a)(1)(A)(iii) (2007).

(29) Id.

(30) Id.

(31) Id.

(32) Id.

(33) 8 C.F.R. [section] 204.2 (c)(1)(iv)(2007).

(34) Office of Programs, Deferred Action for Self-Petitioning Battered Spouses and Children with Approved I-360 Petitions (December 22, 1998).

(35) General Counsel, "Extreme Hardship" and Documentary Requirements Involving Battered Spouses and Children (October 16, 1998).

(36) Pub. L. No. 106-386, Div. A, 114 Stat. 1464 (October 28,2000).

(37) I.N.A. [section] 245(1), 8 U.S.C. [section] 1255(1) (2001).

(38) I.N.A. [sub section] 101(a) (15) (U), 214(p), 245(m).

(39) I.N.A. [section] 208; 8 C.F.R. [section] 208.1

(40) Id.

(41) Sudha Shetty & Janice Kaguyutan, Immigrant Victims of Domestic Violence: Cultural Challenges and Available Legal Protections, vaWnet (February 2002), available at www.new.vawnet.org/Assoc_ Files_VAWnet/AR_immigrant.pdf.

(42) 33 U.S.C. [section]7102 (2007).

(43) Florida State University, Center for the Advancement of Human Rights Human Trafficking Project, Florida Responds to Human Trafficking (Fall 2003).

(44) I.N.A. [section] 101(a) (T)(i).

(45) V.T.V.P.A., [section] 107(b)(1)(E)(1).

(46) The Violence Against Women and Department of Justice Reauthorization Act (2005).

(47) Pub. L. No. 109-162, 199 Stat. 3066, Title VIII, Subtitle D (Jan 5. 2006), codified at 8 U.S.C. [section] 1375a; I.N.A. [section] 214(r)(3)(C).

(48) Lewis Kamb & Robert L. Jamieson, Jr., Mail Order Bride's Dream of a Better Life Ends in Death, Seattle Post Intelligencer, February 2, 2001, available at seattlepi.nwsource.com/local/brid02. shtml.

(49) Kerry Abrams, Immigration Law and the Regulation of Marriage, 91 Minn. L. Rev. 1625, n. 23 (2007).

(50) I.N.A. [section] 214 (d)(2)(A).

(51) Kerry Abrams, Immigration Law and the Regulation of Marriage, 91 Minn. L. Rev. 1625, n. 23 (2007).

(52) Sudha Shetty & Janice Kaguyutan, Immigrant Victims of Domestic Violence: Cultural Challenges and Available Legal Protections, VAWNet at n. 43. (February 2002), available at www.new.vawnet. org/Assoc_Files_VAWnet/AR_immigrant. pdf.

Sarah Rebecca Sullivan is a senior staff attorney with Jacksonville Area Legal Aid, Inc. and practices in the areas of family, elder and health care law. She is the vice chair of the Family Law Section's Domestic Violence Committee and is a member of the Legislative and Children's Issues committee. Previously, Ms. Sullivan participated in the Florida Coalition Against Domestic Violence Legal Clearinghouse and a former member of the Mayor's Task Force Against Domestic Violence that created a "one-stop" domestic violence office for victims seeking protective orders in Duval County.

Amy L. Cosentino has worked for the Florida Attorney General's Office, the Palm Beach County State Attorney's Office, and has practiced family law in the West Palm Beach area. Ms. Cosentino currently has her own practice in West Palm Beach. She is secretary of The Florida Bar Family Law Section's Domestic Violence Committee. Ms. Cosentino received a B.A. in dance performance from the University of South Florida and law degree from Nova Southeastern University.