Justia New Jersey Supreme Court Opinion Summaries

Rosalyn Musker worked in sales for Suuchi, Inc., which sells software subscriptions to apparel manufacturers. In addition to her base salary, Musker was eligible for commissions under Suuchi’s Sales Commission Plan (SCP). In March 2020, Suuchi decided to sell Personal Protective Equipment (PPE) on a commission basis due to the COVID-19 pandemic. Musker generated approximately $34,448,900 in gross revenue by selling PPE. The parties disputed whether her 4% commission was based on gross or net revenue and whether these commissions were considered "wages" under the Wage Payment Law (WPL) or excluded as "supplementary incentives."The trial judge dismissed Musker’s WPL claims, holding that her PPE commissions were not "wages" under the WPL. The Appellate Division affirmed this decision, agreeing that the commissions were "supplementary incentives" and not "wages" under the WPL. Musker appealed the decision.The Supreme Court of New Jersey reviewed the case. The Court held that under the WPL, "wages" are defined as "direct monetary compensation for labor or services rendered by an employee, where the amount is determined on a time, task, piece, or commission basis." The Court concluded that compensating an employee by paying a "commission" for "labor or services" always constitutes a wage under the WPL. Therefore, a "commission" cannot be excluded from the definition of "wages" as a "supplementary incentive."The Supreme Court of New Jersey reversed the Appellate Division’s judgment, vacated the trial judge’s order dismissing Musker’s WPL claims, and remanded the case for further proceedings. The Court clarified that Musker’s PPE commissions are "wages" under the WPL, regardless of whether they are based on gross or net revenue, and that receiving a base salary does not turn "commissions" into "supplementary incentives." View "Musker v. Suuchi, Inc." on Justia Law

Crystal Walcott Spill's estate and beneficiaries filed a wrongful death suit against several doctors, including Dr. Steven Paganessi and his medical group, alleging negligence during a surgical procedure that led to Spill's death. Spill, who had lupus, was under the care of Dr. Jenny Diep, a New York-based rheumatologist, and Dr. Jacob Markovitz, a New Jersey-based gynecologist. Before the surgery, Dr. Diep increased Spill's blood pressure medication dosage and recommended she see a nephrologist. Spill saw Dr. Holly Koncicki, a New York-based nephrologist, who conducted lab tests but did not receive the results before the surgery. Spill suffered a cardiac event during the procedure and died the same day. The lab results, available after her death, showed critically elevated creatinine and potassium levels.The trial court dismissed Dr. Diep from the case due to lack of personal jurisdiction and denied the defendants' motion to include her on the verdict form for fault allocation. The Appellate Division affirmed, holding that an out-of-state individual over whom New Jersey courts lack personal jurisdiction cannot be included for fault allocation.The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division's decision, with modifications. The Court held that an individual outside New Jersey's jurisdiction is not a "party" under the Comparative Negligence Act (CNA) for fault allocation purposes. However, such an individual may be considered a joint tortfeasor under the Joint Tortfeasors Contribution Law (JTCL), allowing defendants to seek contribution in a relevant jurisdiction if a judgment is rendered against them. The Court did not agree with the Appellate Division's view that the model civil jury instruction on causation mitigates any unfairness to the defendants. View "Estate of Spill v. Markovitz" on Justia Law

In this case, the plaintiff, D.T., alleged that he was sexually abused by Michael J. McCarthy, a priest assigned by the Archdiocese of Philadelphia, during an overnight trip to a private home in New Jersey in 1971. D.T. claimed that McCarthy, who was a family friend and mentor, used his position as a priest to gain the trust of D.T.'s mother and take him on the trip where the abuse occurred. The Archdiocese, which operates in Pennsylvania, argued that it did not own property or conduct business in New Jersey at the time of the alleged incident.The trial court granted the Archdiocese's motion to dismiss the complaint for lack of personal jurisdiction. The Appellate Division twice remanded the case for jurisdictional discovery and consideration of the Archdiocese's past ownership of property in New Jersey. After the second remand, the trial court again granted the motion to dismiss, and the Appellate Division affirmed, finding no basis for personal jurisdiction.The Supreme Court of New Jersey reviewed the case and held that D.T. had not demonstrated that the Archdiocese's supervisory authority over McCarthy established the minimum contacts with New Jersey necessary to exercise specific jurisdiction under Fourteenth Amendment due process principles. The Court found that the Archdiocese did not purposefully avail itself of conducting activities in New Jersey and that McCarthy's actions were not directed by the Archdiocese. The Court affirmed the Appellate Division's judgment, concluding that there was no basis for New Jersey to exercise personal jurisdiction over the Archdiocese in this case. View "D.T. v. Archdiocese of Philadelphia" on Justia Law

Michael Jones purchased Series EE federal savings bonds during his marriage to Jeanine Jones, designating her as the pay-on-death beneficiary. Upon their divorce, their divorce settlement agreement (DSA) did not specifically address the savings bonds but included a provision that any marital asset not listed would belong to the party currently in possession. The DSA also required Michael to pay Jeanine $200,000 in installments. After Michael's death, Jeanine redeemed the savings bonds and filed a creditor’s claim against Michael’s Estate for the remaining $100,000 owed under the DSA. The Estate argued that the redemption of the savings bonds satisfied Michael’s financial obligations to Jeanine.The trial court agreed with the Estate, ruling that the savings bonds counted towards Michael’s $200,000 obligation under the DSA and dismissed Jeanine’s claim for reimbursement. Jeanine appealed, and the Appellate Division reversed the trial court’s decision. The appellate court held that the federal regulations governing U.S. savings bonds preempted state law, and Jeanine was the sole owner of the bonds at Michael’s death. Therefore, the value of the redeemed bonds should not be credited towards the Estate’s obligations under the DSA.The Supreme Court of New Jersey reviewed the case and held that preemption was not an issue because N.J.S.A. 3B:3-14 does not conflict with federal regulations governing U.S. savings bonds. The Court found that the DSA did not direct the disposition of the savings bonds, and thus, the bonds should not be credited against Michael’s $200,000 obligation. The Court affirmed the Appellate Division’s judgment as modified, ruling that the Estate must make the remaining payments to Jeanine as required by the DSA. View "In the Matter of the Estate of Jones" on Justia Law

Plaintiffs, administrators of the Estate of April Carden, filed a medical malpractice complaint against Hackensack Meridian Health, Dr. Alok Goyal, and South Plainfield Primary Care. They alleged that Carden's death was due to Allopurinol prescribed by Dr. Goyal, claiming negligence and vicarious liability. Dr. Goyal and SPPC's answer included a Specialty Statement indicating they practiced internal medicine and gastroenterology. Plaintiffs provided an affidavit of merit (AOM) from Dr. Fitzgibbons, a board-certified internist. Defendants argued Dr. Fitzgibbons was unqualified as she was not certified in gastroenterology.The trial judge denied defendants' motions to dismiss, finding the treatment involved internal medicine. Alternatively, the judge ruled that the AOM from Dr. Fitzgibbons was sufficient under Buck v. Henry. Defendants' motion for reconsideration was also denied. The Appellate Division reversed, requiring an AOM from a physician certified in each of Dr. Goyal's specialties, and remanded for further proceedings.The Supreme Court of New Jersey reviewed the case. It held that when a defending physician practices in multiple specialties, an AOM from a physician specializing in any one of those specialties suffices. The Court found that Dr. Goyal's treatment involved both internal medicine and gastroenterology, and thus, the AOM from Dr. Fitzgibbons, a board-certified internist, was adequate. The Court reversed the Appellate Division's judgment and remanded for further proceedings, emphasizing that plaintiffs must still prove negligence at trial. View "Wiggins v. Hackensack Meridian Health" on Justia Law

Antonio Fuster went to the Chatham Township Police Department to report that his special needs child had accused an adult male relative of sexual misconduct. His interview with police was recorded on a body worn camera. Fuster and his wife, Brianna Devine, sought access to that video under the Open Public Records Act (OPRA) and the common law right of access. They alleged inaccuracies in the initial police report and wanted the video to potentially file an internal affairs complaint.The trial court ruled in favor of the defendants, holding that the body worn camera footage was a government record under OPRA but exempt from disclosure under N.J.S.A. 47:1A-9(b), which protects the confidentiality of information regarding individuals not arrested or charged. The Appellate Division affirmed, concluding that the video was exempt from disclosure under judicial case law protecting uncharged individuals' law enforcement records.The Supreme Court of New Jersey reviewed the case. The Court held that N.J.S.A. 40A:14-118.5(k) did not permit plaintiffs to review the video because Fuster had already requested the video be retained for three years, and Devine was not entitled to review it under the specified provisions. The Court also held that subsection (l) of the Body Worn Camera Law did not abrogate OPRA’s exemptions, but there was no OPRA exemption supporting the refusal to release the video. The Court found that OPRA does not contain an explicit exemption for information received by law enforcement regarding an individual who was not arrested or charged, and New Jersey case law had not established such an automatic grant of confidentiality.The Supreme Court reversed the Appellate Division’s judgment and ordered the release of the body worn camera footage to the plaintiffs, without reaching the common law claims. View "Fuster v. Township of Chatham" on Justia Law

The case involves a car accident where Thomas Irwin rear-ended Linda Brehme's vehicle. Brehme's Personal Injury Protection (PIP) carrier paid benefits but not up to the policy limits. Brehme filed a personal injury complaint against Irwin, seeking damages for pain and suffering, disability, impairment, loss of enjoyment of life, and past lost wages. At trial, Brehme attempted to admit evidence of her projected future medical expenses, but the trial judge denied the motion because she had not exhausted her PIP limits. The jury awarded Brehme $225,000 for pain and suffering and $50,000 for past lost wages, totaling $275,000. Irwin's carrier paid the final judgment, and Brehme's counsel signed a warrant to satisfy the judgment.The Appellate Division dismissed Brehme's appeal as moot, noting that she had accepted and received the full judgment amount and signed a warrant to satisfy the judgment before indicating her desire to appeal. The court found that Brehme's acceptance of the judgment precluded her from appealing the trial judge's ruling barring evidence of future medical expenses.The Supreme Court of New Jersey reviewed the case and held that a plaintiff who accepts a final judgment may still appeal if they can show that they made their intention to appeal known before accepting payment and executing the warrant to satisfy the judgment, and that prevailing on the appellate issue will not impact the final judgment other than to potentially increase it. The court found that Brehme did not express her intention to appeal before accepting payment and executing the warrant, and that the issue of future medical expenses was not separable from the underlying final judgment. Therefore, the appeal was properly dismissed as moot. The court affirmed the Appellate Division's decision and referred the matter to the Civil Practice Committee to assess whether to clarify Rule 4:48-1. View "Brehme v. Irwin" on Justia Law

In 1991, Celestine Payne poisoned her husband, Alphonso, to collect his life insurance policy. She then enlisted her children and a tenant, Eugene Cooper, to help dispose of Alphonso’s body. Two years later, Celestine convinced Cooper to name her the beneficiary of his life insurance policy and then orchestrated an attack on him. When Cooper survived, Celestine went to the hospital, pretended to be his mother, and signed a do-not-resuscitate order. Celestine also fraudulently obtained a life insurance policy on 18-year-old Tara Carter, naming herself as the beneficiary, and later had Tara bludgeoned to death by Charles Pinchom.In 1997, Celestine pled guilty to multiple charges, including two counts of first-degree murder, and was sentenced to two concurrent life terms plus a consecutive 20-year term. In November 2021, Celestine petitioned for compassionate release under the Compassionate Release Act (CRA), citing her permanent physical incapacity. The trial court found she met the Act’s medical and public safety requirements but denied her petition, citing the particularly heinous, cruel, and depraved nature of her crimes as extraordinary aggravating factors.The Appellate Division reversed the trial court’s decision, holding that the facts of the case did not rise to the level of extraordinary circumstances required to deny compassionate release. The court found that the trial court had abused its discretion in its application of the extraordinary aggravating factors.The Supreme Court of New Jersey reviewed the case and held that the trial court’s finding that Celestine’s crimes were extraordinarily heinous, cruel, and depraved was supported by substantial evidence. The Supreme Court found no abuse of discretion in the trial court’s application of the extraordinary aggravating factors and reversed the Appellate Division’s judgment, reinstating the trial court’s denial of compassionate release. View "State v. C.P." on Justia Law

In 1997, Alessandro Roberto purchased a property in Paterson, New Jersey. By 2022, the property was valued at up to $535,000. Roberto failed to pay three sewer tax bills totaling $606, leading the City of Paterson to place tax liens on the property. 257-261 20th Avenue Realty, LLC bought the tax sale certificates at auction. Years later, the company filed a tax foreclosure complaint, and the trial court set the redemption amount at $32,973.15. Roberto did not respond or pay, resulting in a judgment in favor of the plaintiff. Roberto then moved to vacate the judgment, citing his age, the property's equity, and his financial investments in the property. The trial court vacated the judgment under Rule 4:50-1(f), which allows for relief in exceptional circumstances.The Appellate Division affirmed the trial court's decision, influenced by the U.S. Supreme Court's ruling in Tyler v. Hennepin County, which held that a homeowner's surplus equity taken under Minnesota’s tax foreclosure law violated the Fifth Amendment. The Appellate Division concluded that Tyler applied to New Jersey’s Tax Sale Law (TSL) and provided grounds to vacate the judgment. The court also determined that Tyler should be given pipeline retroactivity and found no abuse of discretion in granting relief under Rule 4:50-1(f).The Supreme Court of New Jersey reviewed the case and held that the version of the TSL in effect before its 2024 amendment was unconstitutional to the extent it allowed for the forfeiture of surplus equity without just compensation. The court recognized a property right to surplus equity in New Jersey and determined that private lienholders acting under the TSL could be considered state actors. The court rejected the argument that the surplus equity was not taken for public use and affirmed the Appellate Division's judgment as modified, based on the reasoning in Tyler. View "257-261 20th Avenue Realty, LLC v. Roberto" on Justia Law

Dionicio Rodriguez, an employee of SIR Electric LLC (SIR), was injured while working and filed for workers' compensation benefits under SIR's policy with Hartford Underwriters Insurance Company (Hartford). After receiving benefits, Rodriguez filed a personal injury lawsuit against SIR, alleging negligence, gross negligence, recklessness, and intentional wrongdoing. SIR requested Hartford to defend against the lawsuit, but Hartford refused, citing policy exclusions. SIR then filed a third-party complaint against Hartford, claiming wrongful disclaimer of defense coverage.The trial court granted Hartford's motion to dismiss SIR's complaint, ruling that the policy excluded intent-based claims. SIR's motion for reconsideration and to amend its complaint, arguing that the policy's enhanced intentional injury exclusion (EII exclusion) violated public policy, was denied. The Appellate Division affirmed the trial court's decision.The Supreme Court of New Jersey reviewed the case and held that Hartford has no duty to defend SIR. The court determined that Rodriguez's claims of negligence, gross negligence, and recklessness are subject to the workers' compensation exclusivity bar and are not covered under Part One of the policy. These claims are also excluded from coverage under Part Two of the policy. Additionally, Rodriguez's claims of intentional wrongdoing are excluded under the policy's EII exclusion.The court concluded that the trial judge properly denied SIR's motion to amend its third-party complaint, as the EII exclusion does not violate public policy. The court affirmed the Appellate Division's judgment, upholding the dismissal of SIR's third-party complaint against Hartford. View "Rodriguez v. Shelbourne Spring, LLC" on Justia Law