Justia New Jersey Supreme Court Opinion Summaries

At issue before the New Jersey Supreme Court was two determinations of the Police and Firemen’s Retirement System (PFRS) Board of Trustees (Board), each involving a police officer’s claim that he was “mentally . . . incapacitated” by a traumatic event within the meaning of N.J.S.A. 43:16A-7(1). In Mount v. Board of Trustees, PFRS, the Board and the Appellate Division panel rejected Officer Christopher Mount’s claim that he was permanently disabled because he witnessed at close range the incineration of three young victims in an explosion after a high-speed motor vehicle collision. The Supreme Court held Mount had proven that he experienced a terrifying or horror-inducing event that met the standard of Patterson v. Board of Trustees, SPRS, 194 N.J. 29 (2008), and that the event was undesigned and unexpected within the meaning of Richardson v. Board of Trustees, PFRS, 192 N.J. 189 (2007). The Court therefore reversed the Appellate Division panel’s judgment and remanded to the panel to decide Mount’s claim that his mental disability was a direct result of that incident. In Martinez v. Board of Trustees, PFRS, the Supreme Court considered the Division’s decision reversing the Board’s denial of accidental disability benefits to Detective Gerardo Martinez, a municipal police department’s hostage negotiator. Martinez claimed that his permanent disability resulted from psychological injuries sustained when a lengthy hostage negotiation ended with the shooting death of the hostage-taker, as he and Martinez spoke by cellphone. The Supreme Court held Martinez did not demonstrate the incident that caused his disability was undesigned and unexpected under the Richardson test, and therefore he was not entitled to accidental disability benefits pursuant to N.J.S.A. 43:16A-7. View "Mount v. Board of Trustees, Police and Firemen's Retirement System" on Justia Law

The issue before the New Jersey Supreme Court in this matter centered on the admissibility of evidence procured from a home after police officers’ warrantless entry. A man was attacked at a bus stop in Willingboro and his cell phone was stolen. He and a police officer tracked the phone’s location to a nearby house using a phone tracking application. Several officers arrived at the house, and one spotted the stolen cell phone’s case through a window. When no one responded to their knocks on the door, the officers entered the house through an unlocked window. Once inside, they performed a protective sweep to determine whether the suspect was inside, and they found defendant, J.A., then seventeen years of age, under the covers of a bed. Shortly thereafter, defendant’s mother and brother arrived home. After the officers explained their investigation, defendant’s mother consented to a search of the house, and defendant’s brother voluntarily retrieved the stolen phone. Defendant was later charged with second-degree robbery for theft of the phone. Defendant moved to suppress the evidence, arguing that the officers’ entry into his home was unconstitutional because the officers entered without a warrant and there were no circumstances that would justify an exception to the warrant requirement. The trial court denied defendant’s motion to suppress, finding that although the officers’ search procedure may have been imprudent, it was ultimately defendant’s brother - without any coercion or duress from law enforcement - who retrieved the cell phone. The Appellate Division affirmed. The Supreme Court disagreed with the appellate panel’s determination that the officers’ warrantless entry was justified by the claimed exigency faced by the officers. However, the Court agreed defendant’s brother’s actions did not constitute state action and were sufficiently attenuated from the unlawful police conduct. Because we find that the brother’s independent actions operated to preclude application of the exclusionary rule to the evidence, the Court did not reach the question of defendant’s mother’s consent to search. Accordingly, the Court modified and affirmed the judgment of the Appellate Division. View "New Jersey in the Interest of J.A." on Justia Law

As a result of their sex-offense convictions, all four defendants were required to serve a special sentence of community supervision for life ("CSL") after completion of their prison terms. The commission of their offenses, the judgments of their convictions, and the commencement of their sentences all preceded passage of the 2014 Amendment to the Violent Predator Incapacitation Act. Before the 2014 Amendment, a violation of the terms of CSL was punishable as a fourth-degree crime. The 2014 Amendment increased a CSL violation to a third-degree crime punishable by a presumptive term of imprisonment, and such a violation converted CSL to parole supervision for life (PSL). After enactment of the 2014 Amendment, all four defendants allegedly violated the terms of their CSL. They were indicted for committing third-degree offenses and faced the increased penalties provided by that Amendment. The trial courts presiding over defendants’ cases concluded that the 2014 Amendment’s enhanced penalties, as applied to defendants, violated the Ex Post Facto Clauses of the United States and New Jersey Constitutions and dismissed the indictments. The Appellate Division affirmed. The New Jersey Supreme Court held the Federal and State Ex Post Facto Clauses barred the retroactive application of the 2014 Amendment to defendants’ CSL violations. The Court affirmed the judgment of the Appellate Division dismissing defendants’ indictments. View "New Jersey v. Hester" on Justia Law

In this appeal, the issue presented for the New Jersey Supreme Court's consideration was whether the Open Public Records Act (OPRA) required disclosure of the names and addresses of successful bidders at a public auction of government property. An auction was held at the Bergen County Law and Public Safety Institute to sell sports memorabilia seized by the Bergen County Prosecutor’s Office. There were thirty-nine successful bidders. Plaintiff William Brennan submitted a request to the Prosecutor’s Office, based on OPRA and the common law, for “[r]ecords of payment received from all winning bidders” and “[c]ontact information for each winning bidder.” The Prosecutor’s Office offered redacted copies of receipts that did not include the buyers’ names or addresses. The Office explained that it had sent the buyers letters to ask if they would consent to disclosure of their personal information. For buyers who consented, the Office represented it would provide unredacted receipts. The trial court directed defendants to release the requested information under OPRA. The Supreme Court determined courts were not required to analyze the "Doe" factors each time a party asserts that a privacy interest exists. "A party must first present a colorable claim that public access to records would invade a person’s reasonable expectation of privacy." Here, defendants could not make that threshold showing. "It is not reasonable to expect that details about a public auction of government property -- including the names and addresses of people who bought the seized property -- will remain private. Without a review of the Doe factors, we find that OPRA calls for disclosure of records relating to the auction." The Court reversed the judgment of the Appellate Division. View "Brennan v. Bergen County Prosecutor's Office" on Justia Law

In this appeal, the issue presented for the New Jersey Supreme Court's consideration was whether the Open Public Records Act (OPRA) required disclosure of the names and addresses of successful bidders at a public auction of government property. An auction was held at the Bergen County Law and Public Safety Institute to sell sports memorabilia seized by the Bergen County Prosecutor’s Office. There were thirty-nine successful bidders. Plaintiff William Brennan submitted a request to the Prosecutor’s Office, based on OPRA and the common law, for “[r]ecords of payment received from all winning bidders” and “[c]ontact information for each winning bidder.” The Prosecutor’s Office offered redacted copies of receipts that did not include the buyers’ names or addresses. The Office explained that it had sent the buyers letters to ask if they would consent to disclosure of their personal information. For buyers who consented, the Office represented it would provide unredacted receipts. The trial court directed defendants to release the requested information under OPRA. The Supreme Court determined courts were not required to analyze the "Doe" factors each time a party asserts that a privacy interest exists. "A party must first present a colorable claim that public access to records would invade a person’s reasonable expectation of privacy." Here, defendants could not make that threshold showing. "It is not reasonable to expect that details about a public auction of government property -- including the names and addresses of people who bought the seized property -- will remain private. Without a review of the Doe factors, we find that OPRA calls for disclosure of records relating to the auction." The Court reversed the judgment of the Appellate Division. View "Brennan v. Bergen County Prosecutor's Office" on Justia Law

During the 2012 mayoral election in the City of Salem, New Jersey, defendant Isaac Young was the executive director of the city’s housing authority. Defendant’s friend and political ally, the incumbent-mayor Robert Davis, was defeated by then-councilman Charles Washington, who was eventually elected mayor. Defendant came into possession of documents sent by the Division of Youth and Family Services to the City’s police chief. The documents advised the chief that the Division had substantiated allegations of child abuse against Washington. The allegations were later deemed to be unsubstantiated. Defendant showed the documents to others in his office and gave copies to a police officer, Sergeant Leon Daniels, so that Daniels could distribute the documents to others for political purposes. Defendant was ultimately charged with permitting or encouraging the release of a confidential child abuse record, a fourth-degree offense; hindering his own apprehension or prosecution by giving a false statement to law enforcement; and fourth-degree false swearing by inconsistent statements. Defendant filed a motion to dismiss the charge relating to the unlawful release of the confidential documents, arguing that N.J.S.A. 9:6-8.10b did not apply to his conduct. The court denied that motion. After a mistrial and retrial, defendant was convicted of the three offenses. An Appellate Division panel affirmed defendant’s convictions for hindering and false swearing. Finding no reversible error in the appellate court's judgment, the New Jersey Supreme Court affirmed. View "New Jersey v. Young" on Justia Law

Defendant Asher Adelman established eBossWatch.com, which published an article, “'Bizarre’ and hostile work environment leads to lawsuit.” The article detailed a gender-discrimination, workplace-harassment, and retaliation lawsuit brought against Petro-Lubricant Testing Laboratories, Inc., and its chief executive officer and co-owner, John Wintermute (collectively Wintermute), by a former employee, Kristen Laforgia. More than a year after the article’s publication, Wintermute’s attorney sent a letter to Adelman, contending that the article was false and defamatory, Laforgia’s complaint was baseless, and that Laforgia and Wintermute had settled the lawsuit. In an email response, Adelman defended the article, stating that it was a reporting of Laforgia’s complaint, with a few modifications that, by Adelman’s opinion, made clear the article reported on what was filed in Laforgia’s complaint. Wintermute still filed a defamation action. The trial court found the modified article fell within the ambit of the fair report privilege and dismissed the defamation lawsuit. The Appellate Division disagreed with the trial court, holding that under the single publication rule, a new statute of limitations began to run only “if a modification to an Internet post materially and substantially alters the content and substance of the article.” The panel reasoned that “if a minor modification diminishes the defamatory sting of an article, it should not trigger a new statute of limitations.” The panel therefore dismissed as untimely Wintermute’s defamation lawsuit filed more than one year following publication of the original article. The panel did not decide whether the fair report privilege barred the action. The Court granted Wintermute’s petition for certification. The New Jersey Supreme Court determined genuine issues of disputed fact remained concerning whether Adelman made a material and substantive change to the original article, and the Appellate Division erred in dismissing the defamation action based on the single publication rule. However, the Court found the modified article was entitled to the protection of the fair report privilege. The article was a full, fair, and accurate recitation of a court-filed complaint. The trial court properly dismissed the defamation action, and on that basis the Supreme Court affirmed the Appellate Division’s judgment. View "Petro-LubricantTesting Laboratories, Inc. v. Adelman" on Justia Law

The New Jersey State Health Benefits Commission (SHBC) and the School Employees’ Health Benefits Commission (SEHBC) (collectively, the Commissions) administered the New Jersey State Health Benefits Program (SHBP) and the School Employees’ Health Benefits Program (SEHBP), respectively. At issue was the method used by the Commissions to correct erroneously tiered reimbursement rates previously applied to members’ out-of-pocket expenses for out-of-network behavioral health services. In a separate matter involving a single plan member, the tiered reimbursement schedule was determined to have violated N.J.S.A. 52:14-17.46.7, which addressed the calculation of reimbursement rates for out-of-network health benefit services. Following that decision, the Commissions permitted members who paid for out-of-pocket behavioral health services and did not receive a proper reimbursement to obtain retroactive reimbursement for charges incurred between May 2009 and March 2014. The challenge before the New Jersey Supreme Court centered on the reasonableness of the Commissions’ notice to members who may have been affected by the application of the erroneous reimbursement rates. The Supreme Court reversed the Appellate Division’s holding and remanded the matter to the Commissions for further proceedings. “Significant questions exist concerning the extent of the notice actually provided, either by the Commissions or through their agents to active employees, former employees, and retirees, a hearing is necessary.” View "In the Matter of State and School Employees' Health Benefits Commissions' Implementation of I/M/O Philip Yucht" on Justia Law

In this appeal, the issue this case presented for the New Jersey Supreme Court's review focused on state action based on, among other grounds, the Religious Aid Clause of Article I, Paragraph 3 of the New Jersey Constitution, specifically its prohibition against the use of public funds “for the maintenance of any minister or ministry.” The challenge arose following the Secretary of Higher Education’s (Secretary) determination to award grant monies to a yeshiva and to a theological seminary as part of a state program to subsidize facility and infrastructure projects for higher education institutions. The Appellate Division determined that prior case law concerning the New Jersey Constitution’s Religious Aid Clause required invalidation of the grants to the yeshiva and theological seminary. The State maintained the proper constitutional analysis in this matter turned on the use to which these higher education institutions would put the monies, not the nature of the institutions themselves. The Supreme Court determined judicial review was premature because factual disputes required resolution before the Secretary could make a properly informed decision on the grant applications. Because an informed administrative decision could not have been made without the benefit of a proper record, the matter was remanded to the Secretary, in order that a contested case proceeding be conducted prior to the ultimate administrative decision of the Secretary concerning the challenged grants. View "American Civil Liberties Union of New Jersey v. Hendricks" on Justia Law

Petitioner Jaclyn Thompson alleged that she was mentally disabled as a result of three incidents at work. Petitioner was a health and physical education teacher. She taught regular gym classes, coached, and served as an advisor and mentor. She also taught gym classes specifically geared toward students with disabilities. During three of petitioner’s classes, students punched, slapped, or pushed her. Petitioner sustained no physical injuries in the three incidents, and she required no medical treatment. Petitioner filed a request for accidental disability retirement benefits based on the three incidents. Her psychiatrist diagnosed her with post-traumatic stress disorder (PTSD). The Board of Trustees of the Teachers’ Pension and Annuity Fund (Board) denied her request for accidental disability benefits but found petitioner qualified for a deferred retirement. Petitioner argued she met the requirement for mental disability because the incidents involved physical contact. An Administrative Law Judge (ALJ) found petitioner did not meet the standard for accidental disability benefits. However, the ALJ granted her ordinary disability benefits. The ALJ found that she suffered from PTSD, that medication was ineffective at abating her symptoms, and that she was totally and permanently disabled from the performance of her regularly assigned duties. Petitioner appealed the denial of accidental disability benefits. The Board affirmed the ALJ. Petitioner then appealed to the Appellate Division. The majority of the panel affirmed. Finding no abuse of discretion, the New Jersey Supreme Court affirmed the Appellate Division. View "Thompson v. Board of Trustees, Teachers' Pension and Annuity Fund" on Justia Law