Justia New Jersey Supreme Court Opinion Summaries

The State charged Ebenezer Byrd, Jerry J. Spraulding, and Gregory A. Jean-Baptiste in connection with a 2009 murder. During their trial in January 2019, allegations arose that Juror No. 8 had conducted outside research, discussed the case with third parties, texted one of the defendants, and expressed an intent to find the defendants guilty. The trial judge questioned Juror No. 8 at sidebar, asking general questions about her impartiality and whether she had been exposed to outside information. Juror No. 8 denied any misconduct. Defense counsel objected to the limited scope of the questioning and requested further inquiry, which the judge denied. The jury convicted the defendants on all counts.On appeal, Byrd’s counsel moved for a limited remand to reconstruct the record regarding Juror No. 8’s alleged misconduct. The Appellate Division ordered a remand hearing, during which the trial judge described the inquiry into Juror No. 8. The Appellate Division affirmed the convictions, holding that the trial judge’s response to the allegations did not constitute an abuse of discretion. The court found that the judge had adequately assessed the juror’s impartiality and that the allegations lacked credibility.The Supreme Court of New Jersey reviewed the case and held that the trial judge’s inquiry into the allegations was inadequate. The Court emphasized that when allegations of juror misconduct arise, the court must conduct a specific and probing examination of the juror. The trial judge failed to ask questions that directly addressed the allegations and did not conduct the inquiry outside the presence of the remaining jurors. The Court reversed the Appellate Division’s judgment and remanded the case for an evidentiary hearing, including individual voir dire of the juror, to determine whether juror taint occurred and whether further steps, including a new trial, are necessary. View "State v. Byrd" 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

In 2019, the defendant pled guilty to multiple counts of burglary and robbery. During the plea colloquy, he falsely claimed to be a U.S. citizen and stated he was born in New York, despite being born in Mexico. The presentence report noted his birthplace as Mexico but left many fields blank. At sentencing, the defendant's counsel, Carol Wentworth, reviewed the report with him, and he confirmed his U.S. citizenship. The court sentenced him to five years of Recovery Court Probation. After violating probation terms, the defendant was sentenced to five years' incarceration.The defendant later filed a petition for post-conviction relief (PCR), claiming ineffective assistance of counsel for not being informed of the immigration consequences of his plea. The PCR court found sentencing counsel ineffective for not investigating discrepancies in the presentence report and granted the petition. The Appellate Division affirmed in part, agreeing that counsel failed to advise the defendant of deportation risks but remanded for further consideration on whether the defendant could withdraw his plea.The Supreme Court of New Jersey reviewed the case and held that sentencing counsel was not constitutionally ineffective. The court found that the counsel's performance was not deficient as the presentence report did not clearly indicate non-citizenship, and the defendant repeatedly asserted his U.S. citizenship. The court emphasized that no court has required independent verification of a client's citizenship status beyond asking the client. The court reversed the Appellate Division's judgment and remanded to the PCR court for entry of an order denying the defendant's petition. View "State v. Hernandez-Peralta" 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

Plaintiff, a person with quadriplegia, purchased cellular service from an Altice retail store in 2019. He was not shown any documents containing arbitration provisions at the time of purchase. Instead, he received a receipt stating that all documents and agreements would be sent electronically to his email. A week later, he bought a phone from the same store and signed a Retail Installment Contract (RIC) that incorporated the terms of the customer service agreement (CSA), which included arbitration provisions. In June 2021, during the COVID-19 pandemic, plaintiff was denied access to an Altice store for not wearing a face mask and the police were called. Plaintiff filed a complaint in October 2022, alleging discrimination and harassment under the New Jersey Law Against Discrimination.The trial court dismissed the complaint and compelled arbitration based on an affidavit from Altice's Senior Director of Business Process Management, which claimed that the CSA would have been emailed to the plaintiff. The Appellate Division affirmed, finding that the parties' conduct evidenced a binding agreement.The Supreme Court of New Jersey reviewed the case and held that under N.J.R.E. 406, evidence of a specific, repeated, and regular business habit or practice is admissible to establish a rebuttable presumption that a business acted in conformity with that habit or practice. However, the court found that Altice produced insufficient evidence of such a habit or practice. The affidavit provided by Altice lacked the necessary specificity to establish that the CSA was emailed to the plaintiff. Consequently, the court did not reach the issue of mutual assent to arbitrate. The judgment of the Appellate Division was reversed, and the case was remanded for trial. View "Fazio v. Altice USA" 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

A journalist, Charles Kratovil, learned through a records request that Anthony Caputo, the New Brunswick Police Director, had a voting address in Cape May. Kratovil, editor of New Brunswick Today, began investigating Caputo's residence, suggesting it was too far from New Brunswick for him to effectively perform his duties. After disclosing Caputo's address to local officials, Caputo informed Kratovil that he was protected under Daniel’s Law and requested that Kratovil refrain from republishing his exact home address. Kratovil then filed a lawsuit seeking declaratory and injunctive relief, claiming that Daniel’s Law violated his constitutional rights to freedom of speech and the press.The trial court dismissed Kratovil’s complaint, ruling that while Kratovil could publish that Caputo lived in Cape May, he could not publish Caputo’s precise home address. The court found that Daniel’s Law was narrowly tailored to serve a state interest of the highest order. The Appellate Division affirmed this decision, agreeing that the statute did not violate constitutional guarantees and that it was narrowly tailored to protect public officials.The Supreme Court of New Jersey reviewed the case, applying First Amendment principles from Smith v. Daily Mail Publishing Co. and Florida Star v. B.J.F. The Court held that Caputo’s home address was truthful information, lawfully obtained, and related to a matter of public concern. The Court agreed that Daniel’s Law served a state interest of the highest order and was narrowly tailored to achieve that interest. The Court affirmed the Appellate Division’s judgment as modified, concluding that Daniel’s Law did not violate constitutional protections of free speech and the press. View "Kratovil v. City of New Brunswick" on Justia Law

The case involves the Attorney General's request to empanel a special grand jury to investigate allegations of sexual abuse by clergy within the Catholic Church in New Jersey. The Diocese of Camden challenged the grand jury's authority to issue a presentment on this subject, arguing that such a presentment would not relate to public affairs or conditions as required by law.The trial court denied the Attorney General's request to empanel a special grand jury and found that the anticipated presentment was not authorized by law. The court cited the substantial commitment of time and resources needed to select unbiased grand jurors, the financial hardship on jurors, and the fact that priests are not public officials and the Catholic Church is not a public entity. The court also noted that the presentment would be fundamentally unfair to those accused, as they would not have the same protections as defendants charged by indictment. The Appellate Division summarily affirmed the trial court's judgment.The Supreme Court of New Jersey reviewed the case and reversed the lower courts' decisions. The Court held that it was premature for the trial court to conclude that any potential presentment had to be suppressed, as no grand jury had completed an investigation or issued a presentment. The Court emphasized that the relevant case law and court rule on presentments contemplate the existence of both a grand jury investigation and an actual presentment for an assignment judge to review. The Court found that the State has the right to proceed with its investigation and present evidence before a special grand jury. If the grand jury issues a presentment, the assignment judge should review the report and publish it if it complies with the legal standards outlined by the Court. The Court vacated the trial court's analysis and remanded the matter for further proceedings consistent with its opinion. View "In re the Matter Concerning the State Grand Jury" on Justia Law

Plaintiff and defendant were married in 2019 and have one son together. Plaintiff moved out of the marital home in January 2023 and initiated divorce proceedings in March 2023. In April 2023, defendant was arrested and charged with weapon offenses after threatening a process server with a handgun. Plaintiff filed a civil complaint in July 2023 under the Prevention of Domestic Violence Act (PDVA), seeking a temporary restraining order (TRO) based on allegations of stalking and harassment. The court issued a TRO prohibiting defendant from contacting plaintiff, granting her temporary custody of their son, and denying defendant parenting and visitation time.During the final restraining order (FRO) hearing, plaintiff called defendant as a witness. Defendant invoked the Fifth Amendment privilege against self-incrimination, but the trial court ordered him to testify. Defendant refused to answer questions beyond stating his name, invoking the Fifth Amendment. The trial court ruled that defendant could not invoke the privilege and that an adverse inference could be drawn from his refusal to testify. Defendant appealed the decision.The Appellate Division denied leave to appeal. While defendant's motion for leave to appeal was pending, the Appellate Division published T.B. v. I.W., addressing a similar issue. The Supreme Court of New Jersey granted defendant leave to appeal.The Supreme Court of New Jersey held that while the Fifth Amendment does not provide blanket immunity in PDVA FRO hearings, a defendant may invoke the privilege against self-incrimination in response to specific questions that pose reasonable risks of self-incrimination. The court ruled that no adverse inference may be drawn from the exercise of this right. The PDVA immunity provision in N.J.S.A. 2C:25-29(a) is not coextensive with the Fifth Amendment and does not adequately protect a defendant's rights. The trial court's ruling was reversed, and the matter was remanded for further proceedings. View "M.A. v. J.H.M." on Justia Law