Coverall North America, Inc. v. New Jersey Department of Labor and Workforce Development

CourtNew Jersey Superior Court Appellate Division
DecidedMay 21, 2026
DocketA-0462-24
StatusUnpublished

This text of Coverall North America, Inc. v. New Jersey Department of Labor and Workforce Development (Coverall North America, Inc. v. New Jersey Department of Labor and Workforce Development) 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.

Bluebook
Coverall North America, Inc. v. New Jersey Department of Labor and Workforce Development, (N.J. Ct. App. 2026).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-0462-24

COVERALL NORTH AMERICA, INC.,

Petitioner-Appellant,

v.

NEW JERSEY DEPARTMENT OF LABOR AND WORKFORCE DEVELOPMENT,

Respondent-Respondent.

Argued April 27, 2026 – Decided May 21, 2026

Before Judges Sabatino, Natali and Bergman.

On appeal from the Commissioner, Division of Unemployment Insurance, Department of Labor and Workforce Development, Agency Docket No. DOL 16- 004.

Norman M. Leon (DLA Piper LLP (US)) of the Illinois and New York bars, admitted pro hac vice, argued the cause for appellant (DLA Piper LLP (US), attorneys; David S. Sager and Norman M. Leon, on the briefs). Nadya Comas, Deputy Attorney General, argued the cause for respondent (Jennifer Davenport, Attorney General, attorney; Sookie Bae-Park, Assistant Attorney General, of counsel; Daniel Resler, Nadya Comas, Yael Fisher, and Sara Vasquez, Deputy Attorneys General, on the brief).

PER CURIAM

Coverall North America, Inc. ("Coverall") appeals a September 9, 2024

final agency decision of the Commissioner of the Department of Labor and

Workforce Development ("the Department") reversing an Administrative Law

Judge's ("ALJ's") decision dated April 24, 2024, in Coverall's favor.

The Commissioner determined that Coverall owed more than $1 million

in unpaid contributions and interest as required by the New Jersey

Unemployment Compensation Law ("UCL"), N.J.S.A. 43:21-1 to -71. The

Commissioner concluded Coverall was the employer of janitorial cleaners and

failed what is commonly known as "the ABC Test" for independent contractor

status.

For reasons that we explain herein, we remand the final agency decision

to address two important points concerning the control of pricing and the

independence of certain individual cleaners.

A-0462-24 2 I.

Because we are remanding the case, we need not describe the facts here

definitively or comprehensively. A short summary will suffice. Before doing

so, we set forth some basic facets of the applicable statutory scheme.

A.

The UCL requires that employers meeting applicable criteria are obligated

to pay certain contributions to the Unemployment and Disabilities Insurance

Funds. N.J.S.A. 43:21-7. Administered by the Department, the program assures

that critical benefits are available to support workers during periods of

unemployment and temporary disability. Ibid.; see also N.J.A.C. 12:17-1.1.

N.J.S.A. 43:21-19(i)(6) provides that "[s]ervices performed by an

individual for remuneration shall be deemed to be employment" under the UCL

unless it is shown by an alleged employer that:

(A) Such individual has been and will continue to be free from control or direction over the performance of such service, both under his contract of service and in fact;

(B) Such service is either outside the usual course of business for which such service is performed, or that such service is performed outside of all the places of business of the enterprise for which such service is performed; and

A-0462-24 3 (C) Such individual is customarily engaged in an independently established trade, occupation, profession or business.

This three-part standard is commonly known as the "ABC Test."1

The ABC Test becomes applicable only after it is determined that the

service provided constitutes employment, defined as "service . . . performed for

remuneration under any contract of hire, written or oral, express or implied. "

N.J.S.A. 43:21-19(i)(1)(A); Carpet Remnant Warehouse, Inc. v. N.J. Dep't of

Lab., 125 N.J. 567, 581 (1991) ("Carpet Remnant"). The concept of

remuneration under the ABC Test is defined as "all compensation for personal

services." N.J.S.A. 43:21-19(p).

The question often presented in disputed cases is whether the workers at

issue performed services for the alleged employer for remuneration. In such an

inquiry, the court "will look behind the contract to the actual situation—the

status in which the parties are placed by the relationship that exists between

1 As we discuss in our factual discussion, the version of the ABC Test pertinent to this case is the version that existed in the audit period from 2006-2008. Recently, the Department prospectively revised the ABC Test regulations distinguishing employees from independent contractors. The new ABC Test will become effective October 1, 2026, and the change does not affect this appeal. See 57 N.J.R. 894(a) (rule adoption notice). A-0462-24 4 them." Gilchrist v. Div. of Emp. Sec., Dep't of Lab. and Indus., 48 N.J. Super.

147, 154 (App. Div. 1957).

Over the years, case law applying the UCL has examined whether the

circumstances (1) involve "remuneration" and, if so, (2) whether the alleged

employer has proven all three criteria for exclusion under the ABC Test. See,

e.g., E. Bay Drywall, LLC v. N.J. Dep't of Lab. and Workforce Dev., 251 N.J.

477, 495 (2022) (holding the Department had correctly classified certain drywall

installers as employees rather than independent contractors, and reversing a

contrary conclusion reached by the Appellate Division); Carpet Remnant, 125

N.J. at 573-74 (holding that carpet installers were not employees of a carpet

retail company where, among other things, the company posted installation jobs

for the installers but they were not obligated to accept them, the installers could

and did work for other carpet retailers, the installers supplied their own tools,

and the company did not control how the installations would be performed);

Trauma Nurses, Inc. v. Bd. of Rev., 242 N.J. Super. 135, 137 (App. Div. 1990)

(holding that the Department had incorrectly classified nurses as an agency's

employees, where the agency had temporarily placed nurses at hospitals but had

not exercised any control or direction over them).

A-0462-24 5 The parties both cite to AC&C Dogs, LLC v. New Jersey Dep't of Lab.,

332 N.J. Super. 330, 332 (App. Div. 2000), in which a company that rented hot

dog carts to vendors, who then cooked and sold hot dogs to the public, was held

liable by the Department for the payment of unemployment taxes. Generally,

the carts came equipped with hot dogs, buns and condiments; however, the

company did not require that the vendors purchase their food supplies from it.

Id. at 333. The vendors were free to set their own prices and to expand the menu

at whatever prices they deemed to be appropriate. Ibid. The hot dogs were in

no way identified as coming from the company and the vendors were not

required to display any company identification. Id. at 334. In addition, the

company had no power to control the manner or the location where the vendors

conducted their business. Ibid.

We held in AC&C Dogs that the vendors were not providing a service to

the company in exchange for remuneration. Id. at 336. We noted that the

company did not sell the hot dogs to the public but rather received money from

the vendors in the form of a rental charge and the cost of supplies. Ibid. The

money the vendors received was from the public, not from the company.

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Trauma Nurses, Inc. v. Board of Review
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Carpet Remnant Warehouse, Inc. v. New Jersey Department of Labor
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Coverall North America, Inc. v. New Jersey Department of Labor and Workforce Development, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coverall-north-america-inc-v-new-jersey-department-of-labor-and-njsuperctappdiv-2026.