Justia New Jersey Supreme Court Opinion Summaries

Antonio Fuster went to the Chatham Township Police Department to report that his special needs child had accused an adult male relative of sexual misconduct. His interview with police was recorded on a body worn camera. Fuster and his wife, Brianna Devine, sought access to that video under the Open Public Records Act (OPRA) and the common law right of access. They alleged inaccuracies in the initial police report and wanted the video to potentially file an internal affairs complaint.The trial court ruled in favor of the defendants, holding that the body worn camera footage was a government record under OPRA but exempt from disclosure under N.J.S.A. 47:1A-9(b), which protects the confidentiality of information regarding individuals not arrested or charged. The Appellate Division affirmed, concluding that the video was exempt from disclosure under judicial case law protecting uncharged individuals' law enforcement records.The Supreme Court of New Jersey reviewed the case. The Court held that N.J.S.A. 40A:14-118.5(k) did not permit plaintiffs to review the video because Fuster had already requested the video be retained for three years, and Devine was not entitled to review it under the specified provisions. The Court also held that subsection (l) of the Body Worn Camera Law did not abrogate OPRA’s exemptions, but there was no OPRA exemption supporting the refusal to release the video. The Court found that OPRA does not contain an explicit exemption for information received by law enforcement regarding an individual who was not arrested or charged, and New Jersey case law had not established such an automatic grant of confidentiality.The Supreme Court reversed the Appellate Division’s judgment and ordered the release of the body worn camera footage to the plaintiffs, without reaching the common law claims. View "Fuster v. Township of Chatham" 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

In 1991, Celestine Payne poisoned her husband, Alphonso, to collect his life insurance policy. She then enlisted her children and a tenant, Eugene Cooper, to help dispose of Alphonso’s body. Two years later, Celestine convinced Cooper to name her the beneficiary of his life insurance policy and then orchestrated an attack on him. When Cooper survived, Celestine went to the hospital, pretended to be his mother, and signed a do-not-resuscitate order. Celestine also fraudulently obtained a life insurance policy on 18-year-old Tara Carter, naming herself as the beneficiary, and later had Tara bludgeoned to death by Charles Pinchom.In 1997, Celestine pled guilty to multiple charges, including two counts of first-degree murder, and was sentenced to two concurrent life terms plus a consecutive 20-year term. In November 2021, Celestine petitioned for compassionate release under the Compassionate Release Act (CRA), citing her permanent physical incapacity. The trial court found she met the Act’s medical and public safety requirements but denied her petition, citing the particularly heinous, cruel, and depraved nature of her crimes as extraordinary aggravating factors.The Appellate Division reversed the trial court’s decision, holding that the facts of the case did not rise to the level of extraordinary circumstances required to deny compassionate release. The court found that the trial court had abused its discretion in its application of the extraordinary aggravating factors.The Supreme Court of New Jersey reviewed the case and held that the trial court’s finding that Celestine’s crimes were extraordinarily heinous, cruel, and depraved was supported by substantial evidence. The Supreme Court found no abuse of discretion in the trial court’s application of the extraordinary aggravating factors and reversed the Appellate Division’s judgment, reinstating the trial court’s denial of compassionate release. View "State v. C.P." on Justia Law

In 1997, Alessandro Roberto purchased a property in Paterson, New Jersey. By 2022, the property was valued at up to $535,000. Roberto failed to pay three sewer tax bills totaling $606, leading the City of Paterson to place tax liens on the property. 257-261 20th Avenue Realty, LLC bought the tax sale certificates at auction. Years later, the company filed a tax foreclosure complaint, and the trial court set the redemption amount at $32,973.15. Roberto did not respond or pay, resulting in a judgment in favor of the plaintiff. Roberto then moved to vacate the judgment, citing his age, the property's equity, and his financial investments in the property. The trial court vacated the judgment under Rule 4:50-1(f), which allows for relief in exceptional circumstances.The Appellate Division affirmed the trial court's decision, influenced by the U.S. Supreme Court's ruling in Tyler v. Hennepin County, which held that a homeowner's surplus equity taken under Minnesota’s tax foreclosure law violated the Fifth Amendment. The Appellate Division concluded that Tyler applied to New Jersey’s Tax Sale Law (TSL) and provided grounds to vacate the judgment. The court also determined that Tyler should be given pipeline retroactivity and found no abuse of discretion in granting relief under Rule 4:50-1(f).The Supreme Court of New Jersey reviewed the case and held that the version of the TSL in effect before its 2024 amendment was unconstitutional to the extent it allowed for the forfeiture of surplus equity without just compensation. The court recognized a property right to surplus equity in New Jersey and determined that private lienholders acting under the TSL could be considered state actors. The court rejected the argument that the surplus equity was not taken for public use and affirmed the Appellate Division's judgment as modified, based on the reasoning in Tyler. View "257-261 20th Avenue Realty, LLC v. Roberto" 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

In June 2020, the Sussex County Division of Social Services, Office of Adult Protective Services (APS), filed a complaint seeking a plenary guardianship for "Hank," an alleged incapacitated person. Steven J. Kossup was appointed as Hank's attorney, and Brian C. Lundquist was appointed as his temporary guardian. They ensured Hank had stable housing, financial assistance, and medical care. Despite APS's recommendation for a plenary guardian, Kossup and Lundquist argued for a limited guardianship based on Hank's improved circumstances and an expert psychologist's report.The trial court denied the fee applications submitted by Kossup and Lundquist, who sought compensation for their services from APS. The court found no basis for such awards in the Adult Protective Services Act (APS Act) or Rule 4:86-4(e). The Appellate Division affirmed, noting that the APS Act and relevant statutes only authorize fee awards from the estate of the alleged incapacitated person, not from APS.The Supreme Court of New Jersey reviewed the case and affirmed the lower courts' decisions. The Court held that there is no support in the governing statutes, court rules, or case law for fee awards against APS. The American Rule, which requires litigants to bear their own legal costs, applies, and exceptions in Rule 4:42-9(a) and Rule 4:86-4(e) do not authorize fee awards against APS. The Court emphasized the importance of pro bono service in guardianship matters and suggested that attorneys should be informed if they are expected to serve pro bono. The Court also acknowledged the significant contributions of Kossup and Lundquist in securing necessary services for Hank. View "In re A.D." on Justia Law

In August 2018, Thomas Zingis was charged with careless driving and driving while under the influence (DWI). He had a prior DWI conviction from April 2012. In December 2018, the municipal court found Zingis guilty of DWI and sentenced him as a second offender, based on his 2012 conviction. Zingis argued that his first conviction should be disregarded because the State failed to prove it was not based on a Dennis-calibrated Alcotest, referencing the State v. Cassidy decision. The municipal court accepted the prosecutor's representation that Camden was not affected by Dennis's misconduct and sentenced Zingis as a second offender.On appeal, the Law Division also found Zingis guilty and upheld the second-offender sentence. However, the Appellate Division affirmed the conviction but vacated the enhanced sentence, ruling that the State failed to prove beyond a reasonable doubt that Zingis’s 2012 conviction was not based on an inadmissible Alcohol Influence Report (AIR). The case was remanded to a Special Adjudicator to determine which counties were affected by Dennis’s conduct and what notification was provided to affected defendants.The New Jersey Supreme Court reviewed the case and adopted the Special Adjudicator’s findings with modifications. The Court held that in any case where the State seeks an enhanced sentence based on a prior DWI conviction during the period of Dennis’s misconduct, the State must provide discovery to the defendant, including data from Exhibit S-152 and the Dennis Calibration Repository. If the prior conviction involved a Dennis-calibrated Alcotest, the defendant must be given the opportunity to challenge the conviction through post-conviction relief (PCR). The Court also ordered that Exhibit S-152, redacted to exclude personal identifiers, be made publicly available. The judgment of the Appellate Division was affirmed, and the case was remanded to the municipal court for further proceedings consistent with the opinion. View "State v. Zingis" on Justia Law

A.D., a student with disabilities, attended Sparta High School and was designated as having a disability under the IDEA. In early 2019, Sparta informed A.D. that he was in danger of failing several classes, leading to a period of home instruction. A.D.'s parents withdrew him from school, and he subsequently passed the GED, receiving a State-issued high school diploma in April 2019. Despite re-enrolling at Sparta High School and receiving home instruction again, A.D. faced academic challenges and was withdrawn from school multiple times. In May 2021, Sparta denied A.D.'s re-enrollment request, citing his receipt of the State-issued diploma.M.N., A.D.'s mother, requested a due process hearing with the New Jersey Department of Education (DOE). The Administrative Law Judge (ALJ) ruled that A.D.'s State-issued diploma was a "regular high school diploma" under federal regulations, thus ending his entitlement to a FAPE. The Commissioner of the DOE upheld the ALJ's decision, and the Appellate Division affirmed, agreeing that the State-issued diploma met state standards and ended A.D.'s entitlement to a FAPE.The Supreme Court of New Jersey reviewed the case and held that a New Jersey State-issued diploma based on passing the GED is not a "regular high school diploma" under 34 C.F.R. § 300.102(a)(3)(iv). Therefore, a student who receives such a diploma remains entitled to a free appropriate public education under the IDEA. The Court reversed the Appellate Division's decision, concluding that A.D. remains entitled to receive a FAPE, and Sparta must provide it. View "Board of Education of the Township of Sparta v. M.N." on Justia Law

Tennessee Gas proposed constructing a new compressor station (Compressor Station 327) in West Milford Township as part of its East 300 Upgrade Project. The site is within the Highlands Preservation Area, which has stringent environmental standards. Tennessee applied to the New Jersey Department of Environmental Protection (DEP) for a Highlands Applicability Determination (HAD), claiming an exemption under N.J.S.A. 13:20-28(a)(11) (Exemption 11) of the Highlands Water Protection and Planning Act. The DEP issued the HAD, determining that the project qualified for Exemption 11.Food & Water Watch appealed the DEP’s decision, arguing that Exemption 11 should be narrowly construed so that the term “routine” modifies “upgrade.” The Appellate Division agreed, vacating the HAD and remanding the matter to determine if Compressor Station 327 qualifies as a “routine upgrade.” The court emphasized that statutory exemptions should be strictly construed to protect environmental interests and found that “routine” should modify all activities listed in Exemption 11.The Supreme Court of New Jersey reviewed the case and reversed the Appellate Division’s judgment. The Court held that “routine” modifies only “maintenance and operations” and does not modify the other activities listed in Exemption 11, such as “upgrade.” The Court based its decision on the plain language of the statute, its grammatical structure, and the context within the law. The case was remanded to determine if the project is consistent with the goals and purposes of the Highlands Act, considering factors such as the project's location on already disturbed lands. View "In the Matter of Proposed Construction of Compressor Station" on Justia Law

In this consolidated appeal, the court examined whether internal reports and documents created after alleged adverse events at nursing and assisted living facilities are discoverable or privileged under the New Jersey Patient Safety Act (PSA). In the first case, the plaintiff, Madeline Keyworth, claimed injuries from two falls at a skilled nursing facility and sought the facility’s internal incident reports. In the second case, the plaintiffs, Suzanne and Jonathan Bender, sought an incident report regarding an alleged attack on Diane Bender by another resident at an assisted living facility. Both facilities argued that the requested materials were privileged under the PSA’s self-critical-analysis privilege.The trial courts in both cases found that the self-critical-analysis privilege did not apply and ordered the defendants to disclose the materials. The Appellate Division reversed these decisions, concluding that the defendants had complied with the PSA’s procedural requirements, thus making the documents privileged and not subject to discovery.The Supreme Court of New Jersey reviewed the cases and held that the facilities did not comply with the PSA’s procedural requirements. Specifically, the court noted that the PSA requires a patient safety committee to operate independently from any other committee within the facility. The defendants’ certifications revealed that their committees did not adhere to this requirement, as they performed dual functions related to both patient safety and quality assurance. Consequently, the court determined that the disputed documents were not privileged under the PSA and were subject to discovery.The court reversed the Appellate Division’s judgment and remanded the cases to the trial courts for further proceedings consistent with its opinion. The main holding was that the facilities’ failure to comply with the PSA’s procedural requirements meant that the self-critical-analysis privilege did not apply to the disputed documents. View "Keyworth v. CareOne at Madison Avenue" on Justia Law