Supreme Court Opinions

Under the totality of the circumstances in this case, the police acted in an objectively reasonable manner to meet an exigency that did not permit time to secure a warrant. No bright-line rule governs the question of exigency, and determining whether the exigency exception to the warrant requirement applies requires courts to conduct an objective, fact-sensitive analysis. Drawing de novo legal conclusions from the facts found by the trial judge, the Court finds that here, time was of the essence, delay was not reasonable, and seizure of the DVR by the police without a warrant was justified by exigent circumstances.

A valid personal guaranty of a company’s indebtedness requires the signer to unambiguously manifest their intent to be personally bound. There are multiple ways a corporate representative can unambiguously manifest an intent to personally guarantee an underlying agreement. Here, Ferreira did not unambiguously manifest an intent to personally guarantee the underlying corporate agreement.

The Court agrees with the trial courts and Appellate Division that the State has not met its burden in establishing the reliability of SBS/AHT testimony here.

Neither remedy Wilkerson seeks finds support in the statutory scheme.

Constitutional ex post facto prohibitions forbid only punishment beyond what was contemplated at the time the crime was committed. Because the law at the time of Krug’s offenses permitted the Board to consider the same “all existing” information it may now consider, retroactive application of the 1997 amendment to Krug created no risk of additional punishment. The Court therefore rejects Krug’s ex post facto challenge.

Consistent with Swan, the one-year statute of limitations that applies to defamation claims also applies to false light claims. The overlap between the causes of action, in conjunction with the practical considerations and free speech protections, mandates that false light be subject to the same one-year statute of limitations as defamation.

The appropriate standard of review is abuse of discretion. As a result, the Court reverses the judgment of the Appellate Division and remands the case to the trial court for consideration of the prosecutor’s denial under that standard.

N.J.S.A. 2C:39-5(j) falls outside the scope of the Graves Act. It sets forth a distinct substantive offense that must be charged independently, even though it is cognizable only when paired with a corresponding prior offense under N.J.S.A. 2C:39-5(a), (b), (c), or (f).

The expungement statute does not bar release of the report because the IA report is not a criminal record. The expungement statute and the expungement order entered by the Sussex County Superior Court do, however, bar release of any information related to the lieutenant’s arrest, conviction, or the disposition of his criminal case. Counsel for defendants has certified that the IA report in this case contains “information pertaining to [the lieutenant’s] arrest, charges and [the] disposition” of his criminal case. Therefore, pursuant to the expungement statute and order, any such information must be redacted from the IA report. The Court affirms but modifies the Appellate Division’s judgment. It remands to the trial court to perform those redactions in camera and to then conduct the common law balancing test set forth in Rivera on the remainder of the IA report. If the court finds that the “interests that favor disclosure outweigh concerns for confidentiality,” Rivera, 250 N.J. at 135, it must redact the additional information specified in Rivera, id. at 150, and then release the redacted report to plaintiff. As to the sealing of court documents, the Court leaves undisturbed the Appellate Division’s direction

By its plain language, N.J.S.A. 43:16A-12.2 directs that “unpaid benefits” be distributed to the decedent’s estate unless the PFRS member has nominated a beneficiary by “written designation.” Because Isaac made no such designation here, the Board must distribute Isaac’s $208,950.03 in unpaid benefits to his estate in accordance with the statutory mandate.

Under the circumstances presented here, the automobile exception to the warrant requirement did not apply and the police were required to obtain a warrant before searching the car.

Only franchisees can bring suit under the FPA. NJCAR is a trade association whose members consist of franchisee motor vehicle dealerships in New Jersey. NJCAR is not itself a motor vehicle franchisee, and it therefore lacks statutory standing to sue under the FPA.

Based on the CRA’s plain language, as well as the legislative history and fundamental purpose of compassionate release, the Court agrees with the Appellate Division that physical examinations are not statutorily mandated to render a medical diagnosis that complies with the statute. The Court concludes, however, that the DOC’s decision to deny M.R. a Certificate of Eligibility in August 2023 was arbitrary, capricious, and unreasonable. Every applicant seeking compassionate release must be examined for both a terminal condition and a permanent physical incapacity. In this instance, the medical records relied upon by the DOC’s attesting physicians, as well as their corresponding explanations, were insufficient to support the agency’s conclusion that M.R. did not suffer from such a physical incapacity.

The trial judge’s inquiry into the allegations in this case was inadequate. When allegations of juror misconduct arise during trial, the court must assess their plausibility. Once the court is satisfied that the allegations are sufficiently plausible to require questioning, the court is obligated to conduct a specific and probing examination of the juror to determine whether misconduct occurred. Here, the trial judge determined the allegations required an inquiry of the juror but then failed to ask questions that directly addressed the allegations.

The Court finds evidence that the Legislature intended to authorize the supersession of the Paterson Police Department in two statutes: (1) L. 2023, c. 94 (Chapter 94), which the Legislature adopted in the wake of the supersession to facilitate the OIC’s leadership of the Department; and (2) L. 2023, c. 74, the appropriations bill for the fiscal year ending on June 30, 2024, in which the Legislature appropriated funds for the Attorney General’s continued operation of the Department. The Court does not base its holding on other statutes and authorities cited by defendants in support of their argument that the Attorney General has general authority to supersede a municipal police department over local officials’ objections if the Attorney General determines that such an action is warranted. The Court declines to reach the question whether the Attorney General has supersession authority in circumstances other than the specific setting of this case.

Under the circumstances presented here, sentencing counsel was not constitutionally ineffective because her performance was not deficient.

Under the facts as presented in this case, charity care is not an unconstitutional “per se” physical taking of private property without just compensation. It does not grant an affirmative right of access to occupy hospitals; it does not give away or physically set aside hospital property for the government or a third party; and it does not deprive hospitals of all economically beneficial use of their property. Charity care is also not an unconstitutional “regulatory” taking of private property without just compensation. That is due to the highly regulated nature of the hospital industry and the legislatively declared paramount public interest that the charity care program serves. Hospitals remain free to challenge their annual subsidy allocations through administrative channels and to lobby the Legislature to make policy changes that would address more broadly the concerns they raise. But the charity care program does not run afoul of the Takings Clause, and the Court therefore affirms the Appellate Division’s judgment, as modified.

The Court views N.J.S.A. 40A:7-12 to require a planning board to independently evaluate the merits of a deannexation petition and make an objective recommendation to the municipality’s governing body. That did not occur in this case. Plaintiffs met their burden of proof with respect to all three prongs of N.J.S.A. 40A:7-12.1, and the trial court properly ordered deannexation.