Cassandra Gigi Smith v. Newark Community Health Centers, Inc.

CourtSupreme Court of New Jersey
DecidedJune 10, 2026
DocketA-67-24
StatusPublished

This text of Cassandra Gigi Smith v. Newark Community Health Centers, Inc. (Cassandra Gigi Smith v. Newark Community Health Centers, Inc.) 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
Cassandra Gigi Smith v. Newark Community Health Centers, Inc., (N.J. 2026).

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.

Cassandra Gigi Smith v. Newark Community Health Centers, Inc. (A-67-24) (089809)

Argued November 3, 2025 -- Decided June 10, 2026

JUSTICE WAINER APTER, writing for a unanimous Court.

In this appeal, the Court considers whether Newark Community Health Centers, Inc. (NCHC) -- a federally qualified health center founded to “provide affordable, quality healthcare” to underserved populations -- is entitled to immunity under New Jersey’s Charitable Immunity Act (CIA) as an entity “organized exclusively for religious, charitable or educational purposes,” N.J.S.A. 2A:53A-7(a), or is instead entitled only to a $250,000 cap on damages as an entity “organized exclusively for hospital purposes,” id. at -8.

Plaintiff Cassandra Gigi Smith alleges that she slipped and fell as she was leaving the examination room at defendant NCHC’s East Orange location in 2019, sustaining multiple serious and permanent injuries. NCHC moved for summary judgment, arguing that it was entitled to immunity under N.J.S.A. 2A:53A-7(a).

According to its website, NCHC is a federally qualified health center founded “to address growing health disparities plaguing underserved populations in the City of Newark.” Its mission is “to provide affordable, high quality, and accessible healthcare to the communities that we serve.” The mission statement explains that NCHC’s “primary goal is to eliminate health disparities and help people live stronger, healthier, and happier lives.” NCHC’s Certificate of Incorporation states that it was “formed for scientific, educational and charitable purposes” and lists 16 separate purposes. Its 2019 tax return lists $33,819,482 in total revenue, including $51,460 from fundraising events and $51,528 from other contributions, grants, and gifts. NCHC’s chief operating officer testified that as a federally qualified health center, NCHC “work[ed] delivering primary care to patients, regardless of their ability to pay.” NCHC submitted seven flyers publicizing its various events.

The trial court granted summary judgment to NCHC, holding there was no genuine issue of material fact that NCHC was “organized exclusively for religious, charitable or educational purposes.” The Appellate Division affirmed. The Court granted certification. 260 N.J. 564 (2025). 1 HELD: As a provider of medical and dental services, NCHC is organized exclusively for hospital purposes under N.J.S.A. 2A:53A-7(b) and -8. It is therefore entitled only to the cap on damages under N.J.S.A. 2A:53A-8.

1. The CIA provides certain nonprofit entities immunity from negligence claims. As the text of N.J.S.A. 2A:53A-7 makes clear, the main difference between immunity for a nonprofit corporation organized exclusively for “religious, charitable or educational purposes” under subsection (a) -- versus one organized exclusively for “hospital purposes” under subsection (b) -- is that for the former, the “employees, agents, [and] servants” of the nonprofit are also immune, whereas for the latter, they are not. N.J.S.A. 2A:53A-8 then sets forth an exception to immunity for nonprofit corporations organized “exclusively for hospital purposes,” limiting liability “to an amount not exceeding $250,000, together with interest and costs of suit, as the result of any one accident.” N.J.S.A. 2A:53A-10 requires that the CIA “be liberally construed so as to afford immunity . . . as provided herein.” The Court has interpreted Section 10 to mean that it is not the Court’s province to engraft exceptions onto the charitable immunity doctrine. (pp. 12-15)

2. As used in Section 7(a), the terms “educational” and “religious” have limited and commonly understood meanings and should be read literally. The word “charitable,” on the other hand, defies precise definition. Therefore, courts engage in a source-of-funds assessment for entities seeking to prove that they are organized exclusively for charitable purposes. The word “exclusively,” as used in Sections 7 and 8, has been interpreted as meaning single or sole. However, ancillary services do not prevent a finding that an entity is organized “exclusively” for religious, charitable, or educational purposes or for hospital purposes. The core question is the dominant motive of the entity. (pp. 16-17)

3. The Court reviews instructive cases, including Kuchera v. Jersey Shore Family Health Center, 221 N.J. 239 (2015). In Kuchera, the plaintiff slipped and fell on “an oily substance” while attending a free eye screening run by the New Jersey Commission for the Blind and Visually Impaired at the Jersey Shore Family Health Center, a part of the Meridian Health system that provided free medical care for underserved communities. Id. at 242-43. Interpreting the words “organized exclusively for hospital purposes,” the Court explained that “[t]he modern hospital is now a place where members of the community” seek not only “emergency services but also preventative services, therapy, educational programs, and counseling.” Id. at 249, 251. Acknowledging that “[t]he education of medical students, physicians, [and] nurses . . . is a significant core hospital purpose,” and that “[t]he provision of charity care,” or medical care to those who cannot afford to pay, was also “a core function of a hospital,” the Court held that the defendants were “organized exclusively for hospital purposes” and could be held liable for negligence up to the damages cap in Section 8. Id. at 254-55. (pp. 18-20) 2 4. The undisputed facts in the record here demonstrate that NCHC is organized exclusively for hospital purposes, not exclusively for educational or charitable purposes. Courts look to an entity’s dominant motive to determine its purpose. Reviewing in detail the evidence NCHC submitted to the trial court, the Court concludes that NCHC’s dominant motive is providing healthcare, not education. Further, NCHC fails any source-of-funding analysis because almost none of its revenue comes from charitable contributions. It is therefore not organized exclusively for charitable purposes. Rather, it is organized exclusively for hospital purposes under Sections 7(b) and 8 of the CIA. The Court explained in Kuchera that a modern hospital is “organized to engage in a series of activities relating to the improvement of human health and the provision of care to the sick, injured, and disabled.” Id. at 252-53. That describes NCHC’s work perfectly. NCHC is therefore not entitled to immunity, but to the $250,000 cap on damages under N.J.S.A. 2A:53A-8. (pp. 20-25)

REVERSED and REMANDED for further proceedings.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, PIERRE-LOUIS, FASCIALE, NORIEGA, and HOFFMAN join in JUSTICE WAINER APTER’s opinion.

3 SUPREME COURT OF NEW JERSEY A-67 September Term 2024 089809

Cassandra Gigi Smith,

Plaintiff-Appellant,

v.

Newark Community Health Centers, Inc.,

Defendant-Respondent.

On certification to the Superior Court, Appellate Division.

Argued Decided November 3, 2025 June 10, 2026

Margaret E. Quinlan argued the cause for appellant (Lowenthal & Abrams, attorneys; Margaret E. Quinlan, on the brief).

Jaunice M. Canning argued the cause for respondent (Law Offices of James H. Rohlfing, attorneys; Samuel P. Reisen, on the brief).

Jonathan H. Lomurro argued the cause for amicus curiae New Jersey Association for Justice (Lomurro Munson, attorneys; Jonathan H. Lomurro and Abbott S. Brown, of counsel, Christina Vassiliou Harvey, of counsel and on the brief, and Spencer A. Sink, on the brief).

JUSTICE WAINER APTER delivered the opinion of the Court.

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