Justia New Jersey Supreme Court Opinion Summaries

The Borough of Sea Bright previously operated as a non-operating school district, sending its kindergarten through eighth-grade students to the Oceanport School District and its high school students to Shore Regional High School District. In 2009, following legislative changes, Sea Bright merged with Oceanport for K-8 education, while continuing its relationship with Shore Regional for grades 9-12. In 2022, Sea Bright sought to withdraw from both Oceanport and Shore Regional in order to join with the Boroughs of Highlands and Atlantic Highlands and Henry Hudson Regional High School to form an all-purpose regional school district serving all grade levels. Sea Bright adopted a resolution supporting this proposal.After Sea Bright and other municipalities filed a joint petition for regionalization with the New Jersey Commissioner of Education, Oceanport and Shore Regional challenged Sea Bright’s authority to seek withdrawal under N.J.S.A. 18A:13-47.11(a). The Commissioner of Education determined that Sea Bright was empowered by statute to pursue withdrawal from the two districts. Oceanport and Shore Regional appealed, arguing that merged districts were not included in the statutory authorization for withdrawal. The Superior Court, Appellate Division, affirmed the Commissioner’s decision, holding that Sea Bright was eligible to seek withdrawal and that statutory terms such as “consolidated” and “merged” were not intended to be distinct for this purpose.The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division’s judgment. The Court held that, based on the plain language of the relevant statutes and the legislative intent to promote regionalization, a municipality in Sea Bright’s position is a governing body authorized to pursue withdrawal from a school district to form or enlarge a regional school district under N.J.S.A. 18A:13-47.11(a). The Court did not address whether Sea Bright satisfied other statutory criteria, leaving that determination to the Commissioner of Education if Sea Bright files a petition. View "In the Matter of the Verified Petition for the Proposed Creation of a PK-12 All-Purpose Regional School District" on Justia Law

In November 2018, police and firefighters responded to a fire at the defendant’s home. About forty minutes after their arrival, while the main section of the house remained ablaze, officers seized a digital video recorder (DVR) from the garage attached to the house without first obtaining a warrant. The State alleged that the DVR contained footage relevant to a broader investigation, including suspicion of arson and multiple related homicides. The defendant moved before trial to suppress the DVR, arguing that its warrantless seizure was unconstitutional.The Superior Court, Law Division held a multi-day suppression hearing, heard testimony from several first responders, and reviewed video and photographic evidence. The trial judge found the officers credible but determined that exigent circumstances did not justify the warrantless seizure because the garage fire had been extinguished for about thirty minutes and the garage was physically distant from the still-burning portion of the house. The Appellate Division affirmed, agreeing that the officers had time to secure a warrant and that the facts did not support an objectively reasonable belief that immediate seizure was necessary.The Supreme Court of New Jersey reviewed the case and, applying a de novo standard to the legal conclusions, found that under the totality of the circumstances, the police acted reasonably and that exigent circumstances justified the warrantless seizure of the DVR. The Court explained that no bright-line rule governs exigency, and its determination requires a fact-sensitive analysis. Here, the seriousness of the crime, the urgency of the situation, the difficulty of obtaining a warrant at that hour, and the risk of evidence destruction supported the officers’ actions. The Court reversed the suppression order and remanded for further proceedings. View "State v. Caneiro" on Justia Law

Extech Building Materials, Inc., a supplier, provided building materials to E&N Construction, Inc. under a two-page “Credit Application and Agreement.” Two E&N representatives, including Joaquim G. Ferreira, signed the agreement. Above the signature lines, a paragraph stated that the signers “personally guarantee unconditionally, at all times . . . the payment of indebtedness . . . of the within named firm.” However, the signature lines used the pre-printed words “No Title,” and neither signer specified whether they signed as representatives, individually, or both. E&N later defaulted on payment, and Extech sued, seeking to hold Ferreira personally liable as a guarantor.The Superior Court, Law Division, denied Extech’s motion for summary judgment and granted summary judgment in favor of Ferreira, finding the agreement did not make it clear that the signers were responsible as guarantors for E&N’s debt. Extech appealed, and the Appellate Division reversed, holding that genuine issues of fact about the parties’ intentions precluded summary judgment for Ferreira and Roney. The trial court’s denial of summary judgment to Extech was affirmed. Ferreira then petitioned for certification, which the Supreme Court of New Jersey granted.The Supreme Court of New Jersey held that a valid personal guaranty of a company’s indebtedness requires the signer to unambiguously manifest their intent to be personally bound. It is possible for a single signature to bind both a company and the individual as guarantor, but only if the agreement clearly expresses that intent. In this case, Ferreira did not unambiguously manifest an intent to be personally bound as guarantor. Accordingly, the Supreme Court reversed the Appellate Division and reinstated summary judgment in Ferreira’s favor, as well as dismissal of the complaint against Roney. View "Extech Building Materials, Inc. v. E&N Construction, Inc." on Justia Law

In two separate incidents, young children under the care of their fathers began exhibiting symptoms commonly known as the “triad” associated with Shaken Baby Syndrome/Abusive Head Trauma (SBS/AHT): subdural hematoma, retinal hemorrhages, and encephalopathy. In each case, a child abuse pediatrician diagnosed the children with SBS/AHT. Both fathers were subsequently charged with aggravated assault and child endangerment based on these findings. The State intended to call the diagnosing physician as an expert witness to testify that, to a reasonable degree of medical certainty, the only plausible explanation for the children’s symptoms was shaking by the caregiver. The defense in both cases moved to exclude this testimony, challenging the scientific reliability of the SBS/AHT theory, specifically the claim that shaking alone, without any impact, can cause the observed injuries.In the Superior Court, following a Frye hearing in one case, the trial judge excluded the SBS/AHT expert testimony, concluding that the scientific basis for the diagnosis was not sufficiently reliable under the Frye standard, particularly given the lack of acceptance in the biomechanical community. The other trial court adopted this determination for the related case. The Appellate Division consolidated the appeals and affirmed both trial courts, holding that SBS/AHT testimony based solely on shaking without impact did not meet the required standard of reliability for expert evidence.The Supreme Court of New Jersey reviewed the cases. It held that the State failed to establish that expert testimony diagnosing SBS/AHT based on shaking without impact is generally accepted in both the medical/pediatric and biomechanical engineering communities, as required under Frye. The Court affirmed the exclusion of the expert testimony and upheld the dismissal of the indictment in one case due to insufficient causation evidence without the barred testimony. View "State v. Nieves" on Justia Law

In this case, Denise Wilkerson won the Democratic primary for a council seat in Roselle, New Jersey, by a narrow margin of three votes over Cynthia Johnson. Johnson requested a recount and a recheck, which ultimately reduced Wilkerson’s margin to two votes. Johnson then filed an amended petition contesting the election, arguing that three voters had been improperly denied the right to vote. The trial court initially ordered a new election but, after reconsideration prompted by the Attorney General, removed the requirement for a new election and directed that the Democratic County Committee select the nominee pursuant to N.J.S.A. 19:13-20.Wilkerson appealed the trial court’s September 12 order to the Appellate Division, seeking either a special primary and general election after Election Day or, alternatively, placement of both Democratic candidates on the general election ballot. The Appellate Division affirmed the trial court’s order, upholding the use of the statutory process that allowed the county committee to select the nominee. Wilkerson then filed an emergent application with the Supreme Court of New Jersey, reiterating her requests for extraordinary remedies.The Supreme Court of New Jersey held that neither of Wilkerson’s proposed remedies—holding a special primary and general election after Election Day or placing both Democratic candidates on the general election ballot—finds support in the statutory scheme. The Court determined that the relevant statutes, N.J.S.A. 19:13-18 and N.J.S.A. 19:13-20, govern the situation, and that the county committee’s selection of the nominee was proper, even though the statutory deadline was relaxed due to litigation delays. The judgment of the Appellate Division was affirmed. View "Johnson v. Wilkerson" on Justia Law

In 1973, Fred Krug committed murder and other violent crimes while on parole, leading to his conviction and a life sentence plus additional consecutive terms. Over the years, Krug accumulated numerous disciplinary infractions in prison but had maintained a largely clean record since 2003, aside from a single incident in 2017. He was denied parole in 1994, 1995, 2012, and 2016. In 2022, at age 75, Krug became eligible for parole again. A two-member panel of the New Jersey State Parole Board denied his application in 2023, citing both old and new information, including his criminal history and institutional behavior, and set his next eligibility for thirty-six months later.Krug appealed the denial to the full Parole Board, arguing that the panel violated the 1979 Parole Act by failing to present new evidence since his last denial, as that Act required only “new information” to be considered at subsequent hearings. The full Board affirmed the denial, explaining that a 1997 amendment had removed the new-information limitation, allowing consideration of the entire record at each hearing. Krug then appealed to the Superior Court, Appellate Division, which upheld the Board’s decision, relying on its earlier ruling in Trantino v. State Parole Board (Trantino V) that the 1997 amendment was a procedural change and did not violate ex post facto protections.The Supreme Court of New Jersey reviewed the case and held that constitutional ex post facto prohibitions bar only punishment beyond what was contemplated at the time the crime was committed. Since the law in effect when Krug committed his offenses (the Parole Act of 1948) permitted the Board to consider all available information, the retroactive application of the 1997 amendment did not increase his punishment. The Court therefore rejected Krug’s ex post facto challenge and affirmed the lower court’s judgment as modified. View "Krug v. New Jersey State Parole Board" on Justia Law

In January 2020, Salve Chipola attended a high school basketball game where Sean Flannery made statements to a school official accusing Chipola of being a drug dealer and providing drugs and alcohol to students. As a result, Chipola was later banned from school grounds and questioned by a police officer about these allegations, which he denied. Flannery admitted to making the statements. Nearly two years after the incident, Chipola filed a lawsuit against Flannery for false light invasion of privacy, alleging that the false statements harmed his reputation and caused emotional distress.The Superior Court of New Jersey, Law Division, granted Flannery’s motion to dismiss, finding that Chipola’s claim was time-barred under the one-year statute of limitations for defamation, as established in Swan v. Boardwalk Regency Corp. The Appellate Division affirmed this decision, reasoning that false light claims are essentially akin to defamation and thus subject to the same one-year limitations period. The court relied on prior case law, including Rumbauskas v. Cantor, which recognized the similarities between false light and defamation claims.The Supreme Court of New Jersey reviewed the case to resolve whether the statute of limitations for false light invasion of privacy should be one year, as for defamation, or two years, as for personal injury. The Court held that the one-year statute of limitations for defamation claims also applies to false light claims. The Court reasoned that the conduct and injuries underlying both torts are closely aligned, and applying a longer limitations period to false light would undermine legislative intent and free speech protections. The judgment of the Appellate Division was affirmed. View "Chipola v. Flannery" on Justia Law

Police responded to a report of gunshots and encountered the defendant walking with two others. When approached by officers, the defendant fled and was seen discarding a loaded handgun. He was apprehended and charged with several offenses, including unlawful possession of a weapon and possession of a weapon for an unlawful purpose, both of which are subject to mandatory minimum sentences under New Jersey’s Graves Act. The defendant, who had no adult criminal convictions, requested a waiver of the mandatory minimum sentence, but the prosecutor denied the request, citing the seriousness of the conduct and the risks posed during the incident.The defendant pled guilty to unlawful possession of a weapon, and the trial court found the aggravating and mitigating factors to be balanced. During sentencing, the court learned of the prior denial of the Graves Act waiver and postponed sentencing for further explanation. The defendant then moved to override the prosecutor’s denial. The Superior Court of New Jersey, Law Division, determined that the defendant had not shown the prosecutor’s decision was a patent and gross abuse of discretion and sentenced him according to the plea agreement. On appeal, the defendant argued that the trial court should have applied the less deferential abuse of discretion standard. The Superior Court of New Jersey, Appellate Division, affirmed, holding that the patent and gross abuse of discretion standard applied.The Supreme Court of New Jersey reviewed the case to determine the correct standard for reviewing a prosecutor’s denial of a Graves Act waiver. The Court held that the appropriate standard is ordinary abuse of discretion, not the heightened patent and gross abuse of discretion standard. The Court reversed the Appellate Division’s judgment and remanded the case to the trial court to reconsider the prosecutor’s denial under the ordinary abuse of discretion standard. View "State v. Taylor" on Justia Law

Police arrested the defendant in August 2021 on an outstanding robbery warrant and found a handgun believed to be his. He was charged with several offenses, including first-degree unlawful possession of a weapon under N.J.S.A. 2C:39-5(b)(1) and (j), the latter applying when a person with a prior conviction subject to the No Early Release Act (NERA) commits an unlawful weapons possession offense. The defendant had a 2017 reckless manslaughter conviction, qualifying as a NERA offense. Pursuant to a plea agreement, he pled guilty to the first-degree weapons charge, and the State recommended a ten-year sentence with a five-year mandatory parole disqualifier under the Graves Act. Defense counsel reserved the right to argue that the Graves Act did not apply to subsection (j).The Superior Court, Law Division, imposed the recommended sentence, including the Graves Act parole disqualifier. On appeal, the Superior Court, Appellate Division, affirmed, reasoning that subsection (j) was a grading statute that elevated the degree of the underlying offense and thus permitted application of the Graves Act’s mandatory minimums. The Appellate Division relied on legislative history and policy arguments, concluding that excluding subsection (j) from the Graves Act would produce an “absurd” result.The Supreme Court of New Jersey reviewed the case and reversed. The Court held that N.J.S.A. 2C:39-5(j) creates a distinct, substantive first-degree offense that must be charged and proven independently, not merely a sentencing enhancement or grading provision. Because the Graves Act does not expressly include subsection (j) among the offenses subject to its mandatory parole ineligibility, a conviction under subsection (j) does not trigger the Graves Act’s mandatory minimums. The case was remanded for resentencing without the Graves Act parole disqualifier. View "State v. Cromedy" on Justia Law

In August 2019, a Jersey City Police Department (JCPD) lieutenant fired a shotgun during an argument with his girlfriend, leading to his arrest and charges of terroristic threats and possession of a weapon for an unlawful purpose. He pled guilty to a lesser charge and completed a pre-trial intervention program. The JCPD conducted an internal affairs (IA) investigation, resulting in a ninety-day suspension for the lieutenant. Plaintiff States Newsroom Inc. sought access to the IA report under the common law.The trial court denied the plaintiff's request, citing the expungement statute and an expungement order that barred the release of information related to the lieutenant’s arrest and criminal case. The court also ordered the entire docket to remain sealed. The Appellate Division reversed and remanded, instructing the trial court to apply the common law balancing test from Rivera v. Union County Prosecutors’ Office and to analyze the sealing of court documents individually.The Supreme Court of New Jersey held that the expungement statute does not categorically bar the release of IA reports but does prohibit the release of any information related to the lieutenant’s arrest, conviction, or criminal case disposition. The Court affirmed the Appellate Division’s judgment with modifications, remanding the case to the trial court to redact such information from the IA report and then conduct the common law balancing test on the remainder. If the court finds that the interests favoring disclosure outweigh confidentiality concerns, it must further redact information as specified in Rivera before releasing the report. The Court also upheld the Appellate Division’s direction regarding the sealing of court documents. View "States Newsroom Inc. v. City of Jersey City" on Justia Law