A-2404-24/a-0338-25 – Jessica Garcia v. Union City Board of Education

CourtNew Jersey Superior Court Appellate Division
DecidedNovember 17, 2025
DocketA-2404-24/A-0338-25
StatusUnpublished

This text of A-2404-24/a-0338-25 – Jessica Garcia v. Union City Board of Education (A-2404-24/a-0338-25 – Jessica Garcia v. Union City Board of Education) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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A-2404-24/a-0338-25 – Jessica Garcia v. Union City Board of Education, (N.J. Ct. App. 2025).

Opinion

RECORD IMPOUNDED

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2404-24 A-0338-25

JESSICA GARCIA,

Plaintiff-Respondent,

v.

UNION CITY BOARD OF EDUCATION, d/b/a UNION CITY HIGH SCHOOL, a/k/a HIGH HALL HIGH SCHOOL,

Defendant-Appellant,

and

FRANCISCO REALPE and PIVOTAL DEVELOPMENTS, LLC,

Defendants. __________________________

JANE DOE,

v. UNION CITY BOARD OF EDUCATION, d/b/a UNION CITY HIGH SCHOOL, a/k/a HIGH HALL HIGH SCHOOL,

Defendants.

Argued October 16, 2025 – Decided November 17, 2025

Before Judges Marczyk and Puglisi.

On appeal from interlocutory orders of the Superior Court of New Jersey, Law Division, Hudson County, Docket Nos. L-1394-21 and L-2710-21.

Todd S. McGarvey argued the cause for appellant (Shah Law Group, LLC, and Chiesa Shahinian & Giantomasi PC, attorneys; Roshan D. Shah, Todd S. McGarvey, Jeffrey S. Chiesa, and Mauro G. Tucci Jr., on the briefs).

Oliver T. Barry argued the cause for respondents (Barry, Corrado & Grassi, PC, attorneys; Oliver T. Barry, on the brief).

PER CURIAM

We granted leave to appeal and consolidate these two related matters for

disposition in a single opinion. Defendant Union City Board of Education

A-2404-24 2 appeals from the trial court's March 5, 2025 orders granting plaintiff Jessica

Garcia's motion for summary judgment on her vicarious liability claim and

denying defendant's motion for summary judgment. Defendant further

challenges the trial court's August 14, 2025 order granting plaintiff Jane Doe's

motion for summary judgment on her vicarious liability claim and denying

defendant's motion for summary judgment.

We address two primary issues on appeal. First, whether the 2019

amendments to the Tort Claims Act (TCA), N.J.S.A. 59:1-1 to :12-3, removed

the scope of employment liability predicate for claims of sexual abuse under

N.J.S.A. 59:2-2(a). Second, we address whether the trial court erred in finding

the 2019 amendments to the Child Victims Act (CVA), N.J.S.A. 2A:14-2a to -

2c, expanded the statute of limitations for claims under the Law Against

Discrimination (LAD), N.J.S.A. 10:5-1 to -50, to events that occurred in 2004.

We reverse in part, affirm in part, and remand for further proceedings.

I.

From 2002 through 2005, defendant employed Francisco "Mike" Realpe

as a full-time physical education teacher and softball coach at Union City High

School, where Garcia and Jane Doe were students. Realpe was Garcia's assistant

softball coach during her junior and senior years. One evening in the spring of

A-2404-24 3 2004, when she was seventeen years old, Realpe brought her into his office after

softball practice and sexually assaulted her.

Realpe was also Jane Doe's gym teacher. In the spring of her senior year

in 2004, Realpe sexually assaulted her in a locker room during an after-school

event.1

Both plaintiffs asserted claims against defendant for negligent

supervision, negligent training, vicarious liability, and hostile educational

environment in violation of the LAD. 2 Following discovery, defendant moved

for summary judgment to dismiss Garcia's claims. Garcia cross-moved for

partial summary judgment with respect to negligent training, negligent

supervision, and vicarious liability. On March 5, 2025, following oral argument,

the trial court denied defendant's motion for summary judgment in its entirety,

and granted, in part, Garcia's affirmative summary judgment motion.

Specifically, the court granted Garcia's motion as to vicarious liability against

defendant for its agent Realpe's sexual abuse of Garcia. It found the 2019

1 Realpe was charged in 2020 and later pled guilty to sexually assaulting Garcia in 2004 and another female student from a different school district in 2019. 2 Plaintiffs asserted other claims that are not relevant to this appeal. Defendant did not move for leave to appeal the denial of its motion for summary judgment regarding the negligent supervision and training claims. A-2404-24 4 amendment to the TCA "disabled immunities that public entities previously

enjoyed from intentional misconduct of their employees in the context of sexual

abuse," and held "employers liable for their employees' intentional misconduct

of a sexual nature outside the scope of employment." It further determined

Garcia's LAD claims were revived under the CVA amendments.

The parties engaged in the same motion practice in Doe's case. The trial

court again denied defendant's motion in its entirety and partially granted Doe's

affirmative motion regarding her vicarious liability claim, finding defendant

liable for Realpe's actions, despite being outside the scope of his employment.

The court likewise found Doe could pursue her LAD claim.

On appeal, the parties are only disputing plaintiffs' claims of vicarious

liability under the TCA and the viability of an LAD claim under the 2019

amendments to the CVA, L. 2019, c. 120, L. 2019, c. 239; N.J.S.A. 2A:14-2a

and -2b.

II.

Defendant argues the trial court erred in granting plaintiffs' affirmative

summary judgment motions on their vicarious liability claims and denying

defendant's summary judgment motions as to this issue, contrary to the TCA and

existing case law. It further contends the trial court erred in denying its motions

A-2404-24 5 for summary judgment regarding plaintiffs' LAD claims, which it asserts were

time-barred and should not have been retroactively applied to the 2004 assaults

in this matter, and that plaintiffs failed to establish a prima facie case for their

hostile educational environment claims.

We review the grant of a motion for summary judgment de novo, applying

the same standard used by the trial court. Samolyk v. Berthe, 251 N.J. 73, 78

(2022). A motion for summary judgment must be granted if "the pleadings,

depositions, answers to interrogatories and admissions on file, together with the

affidavits, if any, show that there is no genuine issue as to any material fact

challenged and that the moving party is entitled to a judgment or order as a

matter of law." Branch v. Cream-O-Land Dairy, 244 N.J. 567, 582 (2021)

(quoting R. 4:46-2(c)). The court must "consider whether the competent

evidential materials presented, when viewed in the light most favorable to the

non-moving party, are sufficient to permit a rational factfinder to resolve the

alleged disputed issue in favor of the non-moving party." Brill v. Guardian Life

Ins. Co. of Am., 142 N.J. 520, 540 (1995).

Additionally, we review rulings of law and issues regarding the

applicability, validity, or interpretation of laws, statutes, or rules de novo. See

Kocanowski v. Twp. of Bridgewater, 237 N.J. 3, 9 (2019). "The Legislature's

A-2404-24 6 intent is the paramount goal when interpretating a statute and, generally, the best

indicator of that intent is the statutory language." Ibid. (quoting DiProspero v.

Penn, 183 N.J. 477, 492 (2005)). "[I]f there is ambiguity in the statutory

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