Justia New Jersey Supreme Court Opinion Summaries

Raquel Ramirez and Jorge Orozco were charged with murder and endangering the welfare of a child in connection with the death of their two-year-old daughter and tried jointly. The prosecution argued in part that defendants were equally responsible for the many injuries their daughter suffered, including the blunt-force head trauma that caused her death, by failing to prevent those injuries. In keeping with that theory of the case, the court instructed the jury on the elements of N.J.S.A. 2C:2-6(c)(1)(c), which governed accomplice liability for the failure to prevent the commission of an offense when under a legal duty to do so. In preparing the jury charge, the trial court looked to the only precedential authority to address that particular section of the accomplice liability statute, New Jersey v. Bass, 221 N.J. Super. 466 (App. Div. 1987). The trial court expressed misgivings about the charge approved in Bass, which seemed to the court to create a “real possibility that a defendant can be convicted as an accomplice of murder without striking a blow and without sharing the purposeful intent to kill.” Nevertheless, noting that Bass remained good law, the court derived its charge to accomplice liability for murder directly from that opinion. The jury acquitted both defendants of murder but convicted each of a lesser included offense: Ramirez of second-degree reckless manslaughter, Orozco of first-degree aggravated manslaughter. The jury found both defendants guilty of endangering. The Appellate Division reversed, and vacated both the manslaughter and the endangering convictions of each defendant. After its review, the New Jersey Supreme Court affirmed as to defendants’ respective manslaughter convictions but reversed as to their convictions for endangerment. Because the jury was improperly instructed as to endangerment, the matter was remanded for a new trial. View "New Jersey v. Ramirez" on Justia Law

M&K Construction (M&K) appealed a workers’ compensation court’s order (the Order) making it reimburse plaintiff Vincent Hager for the ongoing costs of the medical marijuana he was prescribed after sustaining a work-related injury while employed by M&K. Specifically, M&K contends that New Jersey’s Jake Honig Compassionate Use Medical Cannabis Act was preempted as applied to the Order by the federal Controlled Substances Act (CSA). Compliance with the Order, M&K claims, would subject it to potential federal criminal liability for aiding-and-abetting or conspiracy. M&K also claimed medical marijuana was not reimbursable as reasonable or necessary treatment under the New Jersey Workers’ Compensation Act (WCA). Finally, M&K argued that it fit within an exception to the Compassionate Use Act and was therefore not required to reimburse Hager for his marijuana costs. After review, the New Jersey Supreme Court determined: (1) M&K did not fit within the Compassionate Use Act’s limited reimbursement exception; (2) Hager presented sufficient credible evidence to the compensation court to establish that the prescribed medical marijuana represents, as to him, reasonable and necessary treatment under the WCA; and (3) the Court interpretsed Congress’ appropriations actions of recent years as suspending application of the CSA to conduct that complied with the Compassionate Use Act. As applied to the Order, the Court thus found the Act was not preempted and that M&K did not face a credible threat of federal criminal aiding-and-abetting or conspiracy liability. M&K was ordered to reimburse costs for, and reasonably related to, Hager’s prescribed medical marijuana. View "Hager v. M&K Construction" on Justia Law

Plaintiffs filed a putative class action on behalf of themselves and “[a]ll consumers to whom [d]efendants, after November 17, 2013, provided an electronically printed receipt” listing the expiration date of the consumer’s credit or debit card in violation of the Fair and Accurate Credit Transactions Act of 2003 (FACTA). Plaintiffs’ only alleged injury was exposure to an increased risk of identity theft and credit/debit card fraud. The complaint alleged that “there are, at a minimum, thousands (i.e., two thousand or more) of members that comprise the Class.” The trial court granted defendants’ motion to dismiss plaintiffs’ complaint based on its determination that plaintiffs could not satisfy Rule 4:32-1’s numerosity, predominance, or superiority requirements for class certification. The Appellate Division affirmed the dismissal as it pertained to the class action claims. The New Jersey Supreme Court reversed, finding plaintiffs sufficiently pled the class certification requirements to survive a motion to dismiss. The Supreme Court remanded the matter for class action discovery to be conducted pursuant to Rule 4:32-2(a), so that the trial court could determine whether to certify the class. View "Baskin v. P.C. Richard Son, LLC" on Justia Law

In September 2016, defendant Trend Motors, Ltd. (Trend), provided defendant Mary Aquilar with a loaner vehicle for her personal use while her vehicle was being serviced. Aquilar’s negligent operation of the loaner vehicle caused it to strike plaintiff Tyrone Huggins’s car. Huggins sustained serious injuries as a result. GEICO insured Aquilar through an automobile policy. Trend held a garage policy with Federal Insurance Company (Federal) that insured Trend’s vehicles for up to $1,000,000 in liability coverage. The definition of an “insured” in the Federal policy purported to extend liability coverage to Trend’s customers using Trend’s vehicles only if the customer lacked the minimum insurance required by law. Huggins filed a complaint seeking compensation for the injuries and loss of income he suffered as a result of the accident. Federal disclaimed liability, arguing that Aquilar did not fit the policy’s definition of an insured because she held $15,000 in bodily injury coverage through GEICO. The trial court held that the Federal policy’s definition of an insured constituted an illegal escape clause and held Federal to the full policy limit of $1,000,000 in liability coverage. The Appellate Division declined to review the trial court’s ruling. The New Jersey Supreme Court concurred with the trial court’s ruling that the provision in the garage policy at issue constituted an illegal escape clause which could not be used to evade the minimum liability requirements for dealership vehicles set by the Chief Administrator of the Motor Vehicle Commission (MVC). The Court ordered the reformation of Federal’s policy to the $100,000/$250,000 dealer-licensure minimum liability coverage required by N.J.A.C. 13:21-15.2(l). View "Huggins v. Aquilar" on Justia Law

In June 2014, police officers pulled into a parking lot of an abandoned building and found defendants Andrea Dunbrack and Gabriel Rodriguez standing near an unoccupied vehicle. The police observed the victim, N.R., lying on the ground in the fetal position, verbally unresponsive, naked, and bloodied. A small fire was ablaze nearby. N.R.’s clothes were strewn about on the ground and on the front passenger seat of Dunbrack’s car, along with his passport, wallet, and money. A gun stained with N.R.’s blood lay on the driver’s seat, and police later retrieved another gun on Dunbrack’s person. The officers arrested Dunbrack, whose feet had N.R.’s blood on them. Rodriguez fled as police approached, and police later arrested him with N.R.’s cell phone in his pocket. Rodriguez and Dunbrack were charged with robbery, among other offenses, and were tried together. A jury convicted both defendants on all charges. The Appellate Division reversed and remanded for a new trial, holding that the trial court was obligated to give the lesser included theft charge sua sponte because the facts giving rise to that charge were evident from the record. The New Jersey Supreme Court found no error, “let alone plain error,” in the trial court’s omission of a theft charge: “Nothing in Dunbrack’s version of the events ‘jumps off the page’ as indicative of theft. Neither Dunbrack nor Rodriguez requested an instruction on theft, and the trial court was not required to scour the record for a combination of facts to justify giving such a lesser included jury charge.” View "New Jersey v. Dunbrack" on Justia Law

Defendant Luis Masionet was charged with first-degree murder and other offenses in connection with a September 2016 shooting. After learning that his ex-girlfriend and her new boyfriend, Christopher Romero, were expecting a child, defendant went to the store in the outlet mall where Romero worked, pulled out a handgun, and fatally shot Romero. Trial was scheduled to start in late 2017. By then, defendant had been represented by the same assistant deputy public defender for fifteen months. Right before jury selection was to begin, defendant asked the court for an adjournment, stating that, although he would have stayed with his attorney “all the way to the end” if he had taken a plea, “I cannot go to trial with [appointed counsel]” because she had tried only two cases in her career, neither of which were murder trials. The trial judge denied the adjournment request and indicated that appointed counsel would represent defendant through trial. The case proceeded to trial, and the jury convicted defendant on all counts presented. The issue presented for the New Jersey Supreme Court's review was whether defendant's constitutional right to counsel was denied when, on the day his murder trial was set to begin, he sought an adjournment to see if he could hire a private attorney and his request was denied. Like the Appellate Division, the Supreme Court rejected defendant's claim: "If a trial judge does not conduct the proper analysis...it may be necessary to reverse a conviction and start anew. But defendants are not automatically entitled to a new trial. ...the Appellate Division found no abuse of discretion under the circumstances. We agree and affirm defendant's conviction." View "New Jersey v. Maisonet" on Justia Law

In consolidated appeals, the issue they presented for the New Jersey Supreme Court's review centered on whether the Criminal Justice Reform Act (CJRA) empowered judges to detain defendants who were non-citizens to prevent immigration officials from removing them from the country before trial. Defendants Juan Molchor and Jose Rios were arrested and charged with aggravated assault and criminal mischief. Pretrial Services prepared Public Safety Assessments (PSAs) for both defendants, rating both defendants 1 out of 6 for failure to appear (the lowest level of risk), and 2 out of 6 for new criminal activity. Neither defendant had any pending charges, prior convictions, prior failures to appear, or prior juvenile adjudications. Pretrial Services recommended that both be released with monthly reporting. The State moved for pretrial detention, claiming defendants posed a flight risk because they were undocumented immigrants. The State presented no evidence that U.S. Immigration and Customs Enforcement (ICE) was interested in either defendant. The court ordered both defendants detained pretrial, noting that, but for their immigration status, both would likely have been released. The Appellate Division reversed. The Supreme Court agreed with the Appellate Division that the DJRA did not authorize judges to detain defendants to thwart their possible removal by ICE: "it would be preferable for ICE to refrain from deporting defendants while they await trial for many reasons. If removal proceedings occur while a case is pending, we again urge ICE officials to work with prosecutors to allow pending criminal charges to be resolved." View "New Jersey v. Lopez-Carrera" on Justia Law

The New Jersey Office of the Public Defender and the American Civil Liberties Union of New Jersey (ACLU) jointly sought two forms of relief: (1) the release of all defendants detained for six months or longer whose most serious charge is a second-degree offense or lower, with an opportunity for the State to object in individual cases and seek to justify continued detention under an enhanced burden of proof; and (2) new detention hearings under N.J.S.A. 2A:162-19(f) for all defendants detained for six months or longer who were charged with a first-degree offense and entitled to a presumption of release. Movants relied on constitutional and statutory bases in support of their requests, but the New Jersey Supreme Court declined to grant total relief, finding N.J.S.A. 2A:162-19(f) presented a path for individual defendants to argue against continued detention when (1) there is new information, or a change in circumstances, (2) that is material to the release decision. As to the first prong, the Court found “that the worldwide pandemic that has afflicted New Jersey and its prison system amounts to a change in circumstances” within the meaning of Rule 3:21-10(b)(2). "The Judiciary ... will again resume criminal jury trials in person when conditions sufficiently improve. Although there will be a considerable backlog of cases to address, we hope that recent positive developments will enable the criminal justice system to resolve many outstanding criminal charges in a timely manner." View "In the Matter of the Request to Release Certain Pretrial Detainees" on Justia Law

Plaintiff Jed Goldfarb claimed defendant David Solimine reneged on a promise of employment after Goldfarb quit his job to accept the promised position managing the sizeable investment portfolio of defendant’s family. The key issue in this appeal involved whether plaintiff could bring a promissory estoppel claim because he relied on defendant’s promise in quitting his prior employment even though, under New Jersey’s Uniform Securities Law of 1997 (Securities Law or the Act), he could not bring a suit on the employment agreement itself. The New Jersey Supreme Court determined the Securities Law did not bar plaintiff’s promissory estoppel claim for reliance damages. The Court affirmed the liability judgment on that claim and the remanded for a new damages trial in which plaintiff would have the opportunity to prove reliance damages. The Court found he was not entitled to benefit-of-the-bargain damages. To the extent that the Appellate Division relied on an alternative basis for its liability holding -- that a later-adopted federal law “family office” exception had been incorporated into the Securities Law -- the Court rejected that reasoning and voided that portion of the appellate court’s analysis. View "Goldfarb v. Solimine" on Justia Law

Under New Jersey’s Worker’s Compensation Act, an employee injured during a social or recreational activity generally cannot receive compensation for those injuries unless a two-part exception is met. Here, the New Jersey Supreme Court considered whether the injuries sustained by claimant Kim Goulding at an event hosted by her employer were compensable. The workers’ compensation court dismissed Goulding’s claim, determining that "Family Fun Day" was a social or recreational event and that the two-part test of N.J.S.A. 34:15-7 was not satisfied. The Appellate Division affirmed. The Supreme Court reversed, finding the injury Goulding sustained while volunteering at her employer-sponsored event was compensable because, as to Goulding, the event was not a social or recreational activity. Even if N.J.S.A. 34:15-7 was applicable here, Goulding would still have satisfied the two-part exception set forth in that statute. Her role at the event, which was planned to be held annually, was the same as her role as an employee, and but for her employment at Friendship House, Goulding would not have been asked to volunteer and would not have been injured. Thus, Goulding’s injury was “a regular incident of employment.” Furthermore, the Court found Friendship House received a benefit from Family Fun Day “beyond improvement in employee health and morale.” The event was not a closed event for the Friendship House team. Rather, it was an outreach event to celebrate and benefit Friendship House’s clients, creating goodwill in the community. View "Goulding v. NJ Friendship House, Inc." on Justia Law