Justia New Jersey Supreme Court Opinion Summaries

A female custodian employed by a public university filed a Title IX complaint alleging physical assault and a pattern of sexual harassment by a male co-worker, both of whom were members of the same union. The university, which receives federal funding, initiated a Title IX grievance process compliant with 2020 federal Title IX Regulations. After an investigation and hearing in which both parties participated, university decision-makers found the accused violated university policy and determined there was just cause for his termination. The accused’s appeal within the Title IX process was unsuccessful, and he was terminated.The union representing the accused employee filed a grievance under its 2019 collective negotiation agreement (CNA) with the university, seeking arbitration to determine whether the termination was for just cause. The university denied the grievance, arguing that the federal Title IX Regulations preempted the CNA’s grievance procedure. The union sought arbitration through the New Jersey Public Employment Relations Commission (PERC), which denied the university’s request to restrain arbitration and held, applying state preemption law, that the Title IX Regulations did not preempt arbitration. The Superior Court, Appellate Division, affirmed, finding no conflict precluding the union’s grievance procedure.The Supreme Court of New Jersey reviewed the case and reversed the lower courts. The Court held that the CNA’s grievance procedure is preempted by the 2020 federal Title IX Regulations because those regulations require that any grievance or appeal process must apply equally to both complainant and respondent. The CNA’s arbitration process excluded the alleged victim from participation, granting rights only to the accused. The Court concluded that this inequality creates a direct conflict with federal law, which therefore preempts the CNA’s arbitration provision in this context. The decision is limited to this particular CNA and does not preempt all union grievance procedures. View "In the Matter of Rutgers, the State University of New Jersey v. AFSCME Local 888" on Justia Law

In 2005, an individual was convicted of endangering the welfare of a child and placed on Parole Supervision for Life (PSL) in New Jersey. The State Parole Board imposed two special conditions: a ban on accessing social media and a ban on viewing or possessing pornography. In 2018, the individual was arrested on a parole warrant for allegedly violating both conditions. After a hearing, the Parole Board found violations, revoked PSL, and ordered twelve months of incarceration. The individual challenged the constitutionality of the conditions, arguing they violated First Amendment rights. While an appeal was pending, the Parole Board vacated the revocation in February 2020 and later discharged the conditions. On June 1, 2020, the Board issued a decision stating there was no clear and convincing evidence of violations.The complainant and spouse then filed suit under the New Jersey Civil Rights Act (CRA) and the Tort Claims Act (TCA) against the State and others, alleging substantive due process violations, gross negligence, deliberate indifference, and false arrest/imprisonment. The trial court dismissed all claims as time-barred, holding that the statute of limitations began to run at various points before June 2020. The Appellate Division affirmed, finding that the claims accrued earlier and that even under the favorable-termination rule from Heck v. Humphrey, the relevant accrual event was the Board's February 2020 vacatur of the revocation.The Supreme Court of New Jersey held that the favorable-termination rule from Heck v. Humphrey applies to claims under the CRA and the TCA, meaning that civil rights claims that necessarily challenge the validity of a criminal or quasi-criminal proceeding do not accrue until that proceeding is terminated in the plaintiff’s favor. The Court determined that substantive due process and related claims accrued on June 1, 2020, making them timely, but that any false arrest/imprisonment claim accrued earlier and was time-barred. The Court reversed the dismissal of the first three counts and affirmed the dismissal of the false arrest/imprisonment claim. View "C.A.L. v. State of New Jersey" 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 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

A former Newark policeman, Keith Isaac, applied for special retirement in 2013, listing his estranged spouse, Roxanne, as his wife on the application. His retirement was approved in 2016, retroactive to August 1, 2014, resulting in $208,950.03 in unpaid benefits. Isaac passed away before receiving these benefits, and the Division of Pensions and Benefits distributed the unpaid benefits to Roxanne in March 2017. Isaac’s estate requested reconsideration, arguing that the benefits should be paid to the estate. The Board of Trustees of the Police and Firemen’s Retirement System (PFRS) upheld the decision, stating that Isaac had designated Roxanne as his beneficiary.The estate appealed to the Office of Administrative Law (OAL), which affirmed the Board’s decision, reasoning that listing Roxanne as his spouse on the retirement application constituted a beneficiary designation. The estate then appealed to the Appellate Division, which remanded the case to the OAL for a supplemental hearing to determine Isaac’s probable intent regarding the unpaid benefits.The Supreme Court of New Jersey reviewed the case and held that N.J.S.A. 43:16A-12.2 mandates that unpaid benefits be distributed to the decedent’s estate unless a beneficiary is nominated by written designation. Since Isaac did not make such a designation, the Court ruled that the Board’s decision to distribute the benefits to Roxanne was arbitrary, capricious, and unreasonable. The Court reversed the Appellate Division’s decision to remand for further fact-finding and directed that the $208,950.03 in unpaid benefits be distributed to Isaac’s estate. View "Isaac v. Board of Trustees, Police and Firemen's Retirement System" on Justia Law

M.R., an inmate serving a prison sentence for racketeering, experienced significant health issues, including balance problems and difficulty writing. In August 2020, he was diagnosed with a malignant brain tumor and underwent surgery in January 2021. By November 2022, M.R. was wheelchair-bound with residual neurological deficits. In February 2023, M.R. applied for compassionate release under the Compassionate Release Act (CRA). The New Jersey Department of Corrections (DOC) designated two physicians to review his medical records, who provided conflicting diagnoses regarding his terminal condition status. The DOC ultimately denied M.R. a Certificate of Eligibility for compassionate release.M.R. appealed the DOC's decision, and in August 2023, the Appellate Division remanded the case for reevaluation due to the conflicting medical opinions. The physicians provided updated reports, now uniformly concluding that M.R. did not suffer from a terminal condition or permanent physical incapacity, again relying solely on M.R.'s electronic medical records. The DOC reaffirmed its denial of the Certificate of Eligibility. The Appellate Division later affirmed the DOC's decision, concluding that the CRA does not require physical examinations and that the denial was not arbitrary, capricious, or unreasonable.The Supreme Court of New Jersey reviewed the case, focusing on whether the CRA and its implementing regulation require physical examinations for compassionate release applications. The Court held that the CRA does not mandate physical examinations for medical diagnoses. However, the Court found the DOC's decision to deny M.R. a Certificate of Eligibility in August 2023 to be arbitrary, capricious, and unreasonable. The Court emphasized the need for contemporaneous and comprehensive medical evaluations to support such decisions and reversed the Appellate Division's judgment. View "M.R. v. New Jersey Department of Corrections" on Justia Law

In this case, the Attorney General of New Jersey decided to supersede control of the Paterson Police Department following a fatal police shooting. The Attorney General appointed Isa M. Abbassi, a veteran NYPD officer, as the Officer in Charge (OIC) and reassigned the Paterson Police Chief, Engelbert Ribeiro, to the Police Training Commission in Trenton. Plaintiffs, including Paterson officials, challenged the Attorney General's authority to supersede the police department without local consent.The case was first brought to the Law Division, which transferred it to the Appellate Division. The Appellate Division consolidated the actions and ultimately reversed the Attorney General's decision, ruling that the Attorney General exceeded his statutory powers. The appellate court directed the defendants to reassign Ribeiro to Paterson, relinquish control of the department to city officials, and provide a report summarizing their actions and expenditures during the supersession.The New Jersey Supreme Court reviewed the case and found evidence that the Legislature intended to authorize the supersession in two statutes: Chapter 94, which facilitated the OIC's leadership, and the appropriations bill for the fiscal year ending June 30, 2024, which funded the Attorney General's operation of the department. The Court did not base its holding on other statutes or authorities cited by the defendants. The Court reversed the Appellate Division's judgment, finding that the Attorney General's supersession of the Paterson Police Department was not arbitrary, capricious, or unreasonable, and had fair support in the record. The Court did not address whether the Attorney General has general authority to supersede municipal police departments in other circumstances. View "Bulur v. The New Jersey Office of the Attorney General" on Justia Law

A group of hospitals in New Jersey, which serve a high number of low-income patients, challenged the state's charity care program. This program mandates that hospitals cannot refuse patients based on their inability to pay and prohibits billing qualified patients. The hospitals argued that this program constitutes an unlawful taking of private property without just compensation, violating both federal and state constitutional protections.The trial court dismissed some of the hospitals' claims for not exhausting administrative remedies and granted summary judgment to the state on the remaining claims, finding no per se or regulatory takings. The Appellate Division affirmed the summary judgment, agreeing that the charity care program does not effect a taking.The New Jersey Supreme Court reviewed the case and held that the charity care program does not constitute an unconstitutional per se physical taking. The program does not grant an affirmative right of access to hospital property, does not physically set aside hospital property for the government or third parties, and does not deprive hospitals of all economically beneficial use of their property. Additionally, the court found that the program does not amount to a regulatory taking due to the highly regulated nature of the hospital industry and the significant public interest served by the charity care program.The court affirmed the Appellate Division's judgment, as modified, and noted that hospitals can challenge their subsidy allocations through administrative channels and lobby the Legislature for policy changes. The court emphasized that the charity care program does not violate the Takings Clause. View "Englewood Hospital & Medical Center v. State" on Justia Law

Residents of South Seaside Park filed a petition to deannex their community from Berkeley Township and annex it to the Borough of Seaside Park. South Seaside Park is geographically isolated from the mainland section of Berkeley Township, requiring residents to drive 13-16 miles through seven other municipalities to reach the mainland. The community has limited municipal facilities and relies more on Seaside Park for services. The petitioners argued that deannexation would benefit them economically and socially, while not significantly harming Berkeley Township.The Township Council referred the petition to the Planning Board, which conducted 38 hearings over four years. The Planning Board's professional planner, who was supposed to be impartial, instead assisted the Township in opposing the deannexation. Additionally, some Planning Board members made public comments against the petition. The Planning Board ultimately recommended denying the petition, and the Township Council followed this recommendation.Plaintiffs sought judicial review of the Council's decision. The trial court found that the Planning Board's process was biased and that the Township's denial of the petition was arbitrary and unreasonable. The court also found that the denial was detrimental to the economic and social well-being of South Seaside Park residents and that deannexation would not significantly harm Berkeley Township. The Appellate Division affirmed the trial court's decision.The Supreme Court of New Jersey reviewed the case and agreed with the lower courts. It held that the Planning Board failed to conduct an impartial review and that plaintiffs met their burden of proof under N.J.S.A. 40A:7-12.1. The Court affirmed the trial court's order for deannexation, allowing South Seaside Park to seek annexation by Seaside Park. View "Whiteman v. Township Council of Berkeley Township" on Justia Law

The case involves a challenge to the ward map adopted by the Jersey City Ward Commission following the 2020 federal census. The Commission found a 59% population deviation between the most and least populous wards, which exceeded the maximum allowed by the Municipal Ward Law (MWL). The Commission created a new map with a 1.8% deviation and revised the boundaries of all six wards. Plaintiffs, including individuals and community organizations, argued that the new map failed to meet the MWL’s compactness requirement and violated equal protection principles under the New Jersey Constitution. They also claimed a violation of the New Jersey Civil Rights Act (NJCRA).The trial court concluded that the Commission’s map created sufficiently compact wards under the MWL and dismissed the plaintiffs’ statutory and constitutional claims. The Appellate Division reversed the dismissal of the MWL claims, remanding for factfinding on whether the Commission’s determination of compactness had a rational basis. It affirmed the dismissal of the equal protection and NJCRA claims.The New Jersey Supreme Court reviewed the case, focusing on the MWL, equal protection, and NJCRA claims. The Court held that the Commission’s map was a proper exercise of its discretion under the MWL. It found that the Commission was not required to use mathematical measures of compactness or consider communities of interest in its determination. The Court reversed the Appellate Division’s remand for additional factfinding, reinstating the trial court’s judgment on the MWL claim. The Court also affirmed the dismissal of the equal protection and NJCRA claims, concluding that the Commission’s compliance with the MWL negated the equal protection claim and that no statutory or constitutional violation occurred to support the NJCRA claim. View "Jersey City United Against the New Ward Map v. Jersey City Ward Commission" on Justia Law