Christopher Maia v. IEW Construction Group

CourtSupreme Court of New Jersey
DecidedMay 15, 2024
DocketA-3-23
StatusPublished

This text of Christopher Maia v. IEW Construction Group (Christopher Maia v. IEW Construction Group) 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
Christopher Maia v. IEW Construction Group, (N.J. 2024).

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.

Christopher Maia v. IEW Construction Group (A-3-23) (088010)

Argued January 3, 2024 -- Decided May 15, 2024

FASCIALE, J., writing for a unanimous Court.

The Court considers whether plaintiffs’ claims as to conduct that preceded the effective date of L. 2019, c. 212 (Chapter 212), which amended the Wage Payment Law (WPL) and the Wage and Hour Law (WHL), were properly dismissed.

Plaintiffs Christopher Maia and Sean Howarth were employed as laborers for defendant IEW Construction Group, which required them to perform “pre-shift” and “post-shift” work. Maia joined IEW in April 2019. From early May 2019, he was not paid for his “pre-shift” and “post-shift” work. Howarth began working for IEW in April 2020. He was never paid for “pre-shift” and “post-shift” responsibilities. Both Maia and Howarth were laid off in November 2021. In April 2022, they filed a class action complaint alleging in part that IEW violated the WHL and WPL.

The trial judge held that Chapter 212 does not apply retroactively and thus dismissed plaintiffs’ claims for conduct that arose prior to Chapter 212’s effective date of August 6, 2019. The Appellate Division reversed. 475 N.J. Super. 44, 48, 58 (App. Div. 2023). The Court granted leave to appeal. 255 N.J. 282 (2023).

HELD: Chapter 212 is to be applied prospectively to conduct that occurred on or after August 6, 2019 -- Chapter 212’s effective date -- not retroactively to conduct that occurred before that date. The trial judge properly dismissed the portions of the complaint relying on Chapter 212 but arising from conduct prior to its effective date.

1. As a threshold question, the Court considers the Appellate Division’s determination that applying Chapter 212 to conduct occurring prior to its effective date is not a retroactive application, but rather prospective application of a statute “to cases filed after its effective date.” See 475 N.J. Super. at 54-56. Both federal law and state law determine whether a statute’s application is retroactive by focusing on any changes to the legal consequences created by a statute or amendment. In Landgraf v. USI Film Products, the United States Supreme Court clarified that the relevant inquiry is “whether the new provision attaches new legal consequences to events completed before its enactment.” 511 U.S. 244, 269-70 (1994). (pp. 10-12) 1 2. The Court compares the relevant pre- and post-Chapter 212 provisions of the WPL and WHL and finds that comparison telling. By adding liquidated damages and a retaliation claim to both the WPL and WHL, attorneys’ fees to the WPL, and by extending the statute of limitations in the WHL, Chapter 212 allows plaintiffs to bring new claims with enhanced damages that were not previously available to plaintiffs at the time their injuries occurred, thereby changing the legal consequences of acts. The changes are not merely procedural; rather, they affect the duties and liabilities involved. Chapter 212 attaches new legal consequences to events, and applying the provisions of Chapter 212 to conduct “completed before its enactment” would therefore be retroactive application. W.S. v. Hildreth, 252 N.J. 506 (2023), on which the Appellate Division relied, does not lead to a different conclusion because the amendments to procedural requirements at issue there did not create new damages, change the rights, responsibilities, claims, and defenses that parties can assert, or implicate new legal burdens, unlike Chapter 212. (pp. 12-19)

3. Because application of Chapter 212’s provisions to conduct prior to the statute’s effective date would constitute retroactive application, the Court considers whether such application is appropriate. New Jersey courts have long followed a general rule that favors prospective application of statutes. For a statute to apply retroactively, both parts of a two-part test must be satisfied: first, did the Legislature intend to give the statute retroactive application; and second, will retroactive application of the statute “result in either an unconstitutional interference with vested rights or a manifest injustice.” James v. N.J. Mfrs. Ins. Co., 216 N.J. 552, 563 (2014). As to the first question, there are three circumstances that justify applying a statute retroactively: (1) when the Legislature explicitly or implicitly expresses an intent that a law be retroactive; (2) when an amendment is ameliorative or curative; or (3) when the parties’ expectations warrant retroactive application. (pp. 20-23)

4. None of those three circumstances is present here. Indeed, the Legislature expressly stated in Section 14 of Chapter 212 that the new provisions “shall take effect immediately,” a phrase that New Jersey Courts have repeatedly held to signal prospective application. Because the first part of the retroactivity test reveals nothing that warrants a departure from the presumptive prospectivity that applies to substantive legislation, the Court does not reach the second part of the test. For claims based on conduct that occurred prior to August 6, 2019 -- Chapter 212’s effective date -- plaintiffs cannot rely on Chapter 212. (pp. 23-25)

REVERSED. The trial court’s order partially dismissing the complaint is REINSTATED, and the matter is REMANDED for further proceedings.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, SOLOMON, PIERRE-LOUIS, WAINER APTER, and NORIEGA join in JUSTICE FASCIALE’s opinion. 2 SUPREME COURT OF NEW JERSEY A-3 September Term 2023 088010

Christopher Maia and Sean Howarth, on behalf of themselves and all others similarly situated,

Plaintiffs-Respondents,

v.

IEW Construction Group,

Defendant-Appellant.

On appeal from the Superior Court, Appellate Division, whose opinion is reported at 475 N.J. Super. 44 (App. Div. 2023).

Argued Decided January 3, 2024 May 15, 2024

Michael J. Riccobono argued the cause for appellant (Ogletree, Deakins, Nash, Smoak & Stewart, attorneys; Michael J. Riccobono, on the brief).

Amy C. Blanchfield argued the cause for respondents (Mashel Law, attorneys; Stephan T. Mashel, of counsel and on the briefs, and Amy C. Blanchfield, on the briefs).

Thomas F. Doherty argued the cause for amicus curiae New Jersey Business & Industry Association (McCarter & English, attorneys; Thomas F. Doherty, David R. Kott, and Ilana Levin, of counsel and on the brief).

1 James E. Burden argued the cause for amicus curiae National Employment Lawyers Association of New Jersey (McClure Burden, attorneys; James E. Burden, on the brief).

Ravi Sattiraju submitted a brief on behalf of amicus curiae New Jersey Association for Justice (Sattiraju & Tharney, attorneys; Ravi Sattiraju, of counsel and on the brief, and Brendan P. McCarthy, on the brief).

Alex R. Daniel submitted a brief on behalf of amicus curiae The New Jersey Civil Justice Institute (The New Jersey Civil Justice Institute, and White and Williams, attorneys; Anthony M. Anastasio, of counsel, and Alex R. Daniel and Ryan T. Warden, of counsel and on the brief).

John F. Tratnyek submitted a brief on behalf of amicus curiae Academy of New Jersey Management Attorneys (Jackson Lewis, attorneys; John F. Tratnyek and James M. McDonnell, of counsel and on the brief).

JUSTICE FASCIALE delivered the opinion of the Court.

Plaintiffs filed a class action complaint seeking compensation for pre-

and post-shift labor under provisions of L. 2019, c. 212 (Chapter 212), which

amended the Wage Payment Law (WPL), N.J.S.A. 34:11-4.1 to -4.15, and the

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