Justia New Jersey Supreme Court Opinion Summaries

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

The New Jersey Coalition of Automotive Retailers (NJCAR), a trade association representing franchised new car and truck retailers in New Jersey, sued Ford Motor Company. NJCAR alleged that Ford's Lincoln Commitment Program (LCP) violated the Franchise Practices Act (FPA) by creating price differentials among franchisees. NJCAR is not a franchisee itself but represents franchisee members, including Lincoln dealerships.The trial court granted summary judgment in favor of Ford, ruling that NJCAR lacked statutory standing to sue under the FPA because the statute limits the right to sue to franchisees. NJCAR appealed, arguing that it had associational standing to represent its members. The Appellate Division reversed the trial court's decision, holding that NJCAR had associational standing and that New Jersey's liberal standing doctrine did not preclude NJCAR from bringing the suit.The Supreme Court of New Jersey reviewed the case and reversed the Appellate Division's decision. The Court held that the FPA explicitly limits the right to bring a lawsuit to franchisees, as indicated by the statute's language stating that "any franchisee may bring an action against its franchisor." The Court emphasized that the Legislature's intent was clear in restricting the right to sue to franchisees only, and NJCAR, not being a franchisee, lacked statutory standing to bring the suit under the FPA. The Court did not address whether NJCAR would have associational standing under a different cause of action, limiting its holding solely to the FPA. View "New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company" on Justia Law

The Borough of Englewood Cliffs filed a complaint and an amended complaint against its former attorneys and a builder, alleging professional malpractice, breach of contract, unjust enrichment, civil conspiracy, and aiding and abetting. The Borough's actions followed a previous affordable housing litigation where the Borough did not prevail and subsequently settled with the builder. The Borough's new council, elected after a municipal election, pursued the litigation despite warnings from the defendants that the claims were frivolous.The trial court dismissed the Borough's complaints with prejudice, finding that the Borough acted in bad faith to harass, delay, and cause malicious injury. The court awarded the defendants attorney fees and costs under New Jersey’s Frivolous Litigation Statute (FLS), totaling $216,484.45. The Appellate Division affirmed the trial court's decision, concluding that a public entity is not immune from sanctions under the FLS.The Supreme Court of New Jersey reviewed the case and held that municipalities and municipal corporations that engage in frivolous litigation are subject to sanctions under the FLS. The Court found that the FLS does not provide immunity to municipalities and that the doctrine of sovereign immunity does not protect municipalities from liability under the FLS. The Court emphasized that the FLS aims to deter frivolous litigation and compensate the victims of such actions. The judgment of the Appellate Division was affirmed as modified, holding the Borough liable for the sanctions imposed. View "Borough of Englewood Cliffs v. Trautner" 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

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

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

Plaintiff’s daughter, Alexandrianna Lowe, who had an opioid addiction, was admitted to Hackensack Meridian Jersey Shore University Medical Center (JSUMC) for complications related to Type 1 diabetes. Two days later, Lowe was found unresponsive, and hospital staff administered anti-opioid medication but failed to check her blood sugar levels. An autopsy revealed no illicit drugs in her system. Plaintiff filed a complaint against JSUMC and others, alleging negligence. At the time of filing, plaintiff had not been appointed administratrix ad prosequendum of her daughter’s estate and did not have access to Lowe’s medical records.The trial court dismissed Dr. Michael Carson from the case as he was not involved in the events leading to Lowe’s death. Plaintiff submitted an Affidavit of Merit (AOM) by Dr. Joseph Fallon, which defendants argued was insufficient because it did not name the surviving defendants, did not state that Dr. Fallon was a similarly licensed physician, and did not indicate that Dr. Fallon reviewed Lowe’s medical records. Without holding a Ferreira conference, the trial court dismissed the complaint with prejudice for failure to submit a sufficient AOM. The Appellate Division affirmed the dismissal.The Supreme Court of New Jersey reviewed the case and held that the AOM submitted by plaintiff complied with N.J.S.A. 2A:53A-27. The Court found that the AOM statute does not require the affiant to state that they reviewed medical records or to name a specific defendant by name. The Court emphasized the importance of holding a timely and effective Ferreira conference to resolve issues related to the AOM. The Court reversed the Appellate Division’s decision and remanded the case for further proceedings, including consideration of plaintiff’s motion to amend her complaint to add Dr. Vikas Singh as a defendant. View "Moschella v. Hackensack Meridian Jersey Shore University Medical Center" on Justia Law

The case revolves around the University Hospital's decision to award a contract for the design, construction, and operation of an on-site pharmacy to a bidder other than Sumukha LLC. Sumukha challenged the decision, but the hospital's hearing officer denied the protest. Sumukha then appealed to the Appellate Division. While the appeal was pending, Sumukha filed a second protest challenging the decision to change the pharmacy's planned location. When the hospital failed to respond, Sumukha filed a second appeal in the Appellate Division.The Appellate Division dismissed the appeal from Sumukha’s first protest, concluding that University Hospital’s determination was not directly appealable to the Appellate Division. It later dismissed Sumukha’s second appeal. Both dismissals were without prejudice to Sumukha’s right to file an action in the Law Division. The Court granted certification and consolidated the appeals.The Supreme Court of New Jersey found no evidence in University Hospital’s enabling statute that the Legislature intended the Hospital to be a “state administrative agency” under Rule 2:2-3(a)(2). The court held that University Hospital’s decisions and actions may not be directly appealed to the Appellate Division. The court affirmed the dismissal of the appeals, without prejudice to Sumukha’s right to file actions in the Law Division. View "In re Protest of Contract for Retail Pharmacy Design, Construction, Start-Up and Operation, Request for Proposal No. UH-P20-006" on Justia Law

The case involves plaintiffs Christopher Maia and Sean Howarth, who were employed as laborers for defendant IEW Construction Group. The company required them to perform “pre-shift” and “post-shift” work, for which they were not paid. Both Maia and Howarth were laid off in November 2021. In April 2022, they filed a class action complaint alleging that IEW violated the Wage Payment Law (WPL) and the Wage and Hour Law (WHL).The trial judge held that Chapter 212, which amended the WPL and WHL, does not apply retroactively and thus dismissed plaintiffs’ claims for conduct that arose prior to Chapter 212’s effective date of August 6, 2019. The Appellate Division reversed this decision.The Supreme Court of New Jersey granted leave to appeal. The court held that Chapter 212 is to be applied prospectively to conduct that occurred on or after August 6, 2019, not retroactively to conduct that occurred before that date. The trial judge properly dismissed the portions of the complaint relying on Chapter 212 but arising from conduct prior to its effective date. The court reversed the Appellate Division’s judgment, reinstated the trial judge’s order partially dismissing plaintiffs’ complaint, and remanded for further proceedings. View "Maia v. IEW Construction Group" on Justia Law