Borough of Englewood Cliffs v. Thomas J. Trautner

CourtSupreme Court of New Jersey
DecidedMay 7, 2025
DocketA-19-24
StatusPublished

This text of Borough of Englewood Cliffs v. Thomas J. Trautner (Borough of Englewood Cliffs v. Thomas J. Trautner) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Borough of Englewood Cliffs v. Thomas J. Trautner, (N.J. 2025).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Borough of Englewood Cliffs v. Thomas J. Trautner (A-19-24) (089406)

Argued March 17, 2025 -- Decided May 7, 2025

FASCIALE, J., writing for a unanimous Court.

The Court considers a challenge brought by plaintiff Borough of Englewood Cliffs (the Borough) to sanctions imposed by the trial court, which found that the Borough filed a complaint and an amended complaint in bad faith to harass, delay, and cause malicious injury to its former attorneys and a builder. Specifically, the Borough argues that it is immunized from the award of reasonable litigation costs and attorney fees by New Jersey’s Frivolous Litigation Statute (FLS), N.J.S.A. 2A:15-59.1, and the doctrine of sovereign immunity.

Following the Court’s 2015 order requiring judicial oversight of municipal housing obligations to preclude exclusionary development, the Borough filed an action seeking a declaration that it had discharged its constitutional affordable housing obligations. A builder intervened and opposed the motion, and the Borough retained several attorneys as counsel. After assessing the weaknesses of the Borough’s case, the attorneys urged the Borough to settle. The Borough declined that advice and went to trial, but did not prevail. Thereafter, the Borough settled with the builder. The Borough Council passed a Resolution censuring the mayor for pursuing “needless” litigation against the “accurate” warnings of the attorney defendants. The Resolution also praised the attorney defendants. Thereafter, a municipal election occurred during which some new Borough Council members were elected. Under the newly constituted Council, the Borough filed a separate suit against the attorneys and the builder. That action led to this appeal.

Defendants demanded in writing that the Borough withdraw its complaint and amended complaint against them. They described in detail the frivolous nature of the Borough’s pleadings and warned that if the Borough failed to withdraw the complaints, they would file motions to dismiss and seek sanctions. Despite those warnings, the Borough forged ahead.

Thereafter, defendants filed motions to dismiss for failure to state a claim pursuant to Rule 4:6-2(e). The trial judge granted those motions and entered multiple orders dismissing the Borough’s pleadings with prejudice. Defendants also 1 moved for sanctions, and the judge awarded them attorney fees and costs, finding that the Borough acted in bad faith to harass, delay, and cause malicious injury by filing its frivolous pleadings. In total, the Borough was ordered to pay $216,484.45.

The Appellate Division affirmed, concluding, as relevant to the appeal before the Court, that “a public entity is not immune from the sanctions that can be imposed under the FLS.” 478 N.J. Super. 426, 441, 451 (App. Div. 2024). The Court granted certification. 259 N.J. 323 (2024).

HELD: Municipalities and municipal corporations, as defined by N.J.S.A. 1:1-2, that engage in frivolous litigation are subject to sanctions under the FLS. The Supreme Court of the United States has recognized “that municipalities, unlike States, do not enjoy a constitutionally protected immunity from suit,” Jinks v. Richland County, 538 U.S. 456, 466 (2003), and neither the FLS nor any other substantive law in New Jersey has immunized municipalities from FLS liability for filing frivolous pleadings like the Borough was found to have filed here.

1. Enacted in 1988, the FLS serves both a punitive purpose, to deter frivolous litigation, and a compensatory purpose, to reimburse the party that has been victimized by the party bringing the frivolous litigation. The FLS has multiple sections. N.J.S.A. 2A:15-59.1(a)(1) provides that “[a] party who prevails in a civil action, either as plaintiff or defendant, against any other party may be awarded all reasonable litigation costs and reasonable attorney fees, if the judge finds . . . that a complaint, counterclaim, cross-claim or defense of the nonprevailing person was frivolous.” (emphasis added). N.J.S.A. 2A:15-59.1(b) explains the circumstances under which a judge may find that “a complaint, counterclaim, cross-claim or defense of the nonprevailing party was frivolous.” (emphasis added). Reading those provisions in harmony, the Court finds that the Legislature used the terms “nonprevailing person” and “nonprevailing party” interchangeably in the FLS to advance its dual purposes, contrary to the Borough’s argument that it is not a “nonprevailing person” within the meaning of the statute. Further, the Borough would be both a “party” and a “person” under the statute. N.J.S.A. 1:1-2 defines “person” to include “corporations,” and it defines a municipality as a “municipal corporation,” which includes, under the same definition, “cities, towns, townships, villages and boroughs.” Thus, as a plaintiff who filed frivolous pleadings, the Borough is not only “any other party” but also a “person” under N.J.S.A. 2A:15- 59.1(a)(1). The Court parts ways with the Appellate Division to the extent it held otherwise. See 478 N.J. Super. at 442. (pp. 11-16)

2. The Court explains why the Borough’s arguments about the 1995 amendments, which added two sections to the FLS, are unavailing: the Legislature added to the FLS the entirety of subsection (a)(2), which applies to public entities, and the phrase “or public entity” in subsection (c) specifically to address nonparty municipalities 2 who are victimized by defending “present or former employees” against frivolous litigation, not to provide immunity to municipalities that engage in frivolous litigation themselves. The Court also explains that a case in which the Chancery Division held that the Division of Youth and Family Services (DYFS) may not be sanctioned under the FLS does not advance the Borough’s position because DYFS was an executive branch agency, not a municipality. (pp. 17-21)

3. Turning to the doctrine of sovereign immunity, the Court explains that, although the Appellate Division framed the issue as “[w]hether a State and its agencies and political subdivisions are immune from the FLS,” 478 N.J. Super. at 438, the focus in this case is on whether the doctrine of sovereign immunity immunizes municipalities, such as the Borough, from liability under the FLS for engaging in frivolous litigation. It is well-recognized that states have enjoyed state sovereign immunity in federal courts under the Eleventh Amendment of the U.S. Constitution. But “municipalities, unlike States, do not enjoy a constitutionally protected immunity from suit.” Jinks, 538 U.S. at 466. Although the Eleventh Amendment pertains to state sovereign immunity in federal court, it is well-established that states enjoy sovereign immunity from suit in their own courts and may define the scope of that immunity. And municipal immunity is a concept distinct from sovereign immunity under state law as well. (pp. 21-23)

4. In Willis v. Department of Conservation & Economic Development, the Court explained that judicially created immunity protected municipalities from liability when carrying out governmental functions. 55 N.J. 534, 540-41 (1970). In response to Willis, the Legislature enacted the New Jersey Tort Claims Act (TCA), which addressed the immunity of public entities, including certain circumstances in which immunity is waived, in negligence actions -- not municipalities engaging in frivolous litigation.

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Borough of Englewood Cliffs v. Thomas J. Trautner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/borough-of-englewood-cliffs-v-thomas-j-trautner-nj-2025.