In the Matter of P.T. Jibsail Family Limited Partnership Tidelands License Number 1515-06-0012.1 TDI 190001

CourtSupreme Court of New Jersey
DecidedMarch 18, 2026
DocketA-35-24
StatusPublished

This text of In the Matter of P.T. Jibsail Family Limited Partnership Tidelands License Number 1515-06-0012.1 TDI 190001 (In the Matter of P.T. Jibsail Family Limited Partnership Tidelands License Number 1515-06-0012.1 TDI 190001) 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
In the Matter of P.T. Jibsail Family Limited Partnership Tidelands License Number 1515-06-0012.1 TDI 190001, (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.

In the Matter of P.T. Jibsail Family Limited Partnership (A-35-24) (089547)

Argued October 21, 2025 -- Decided March 18, 2026

JUSTICE WAINER APTER, writing for a unanimous Court.

In this appeal, the Court considers whether, under the Tidelands Act, the Tidelands Resource Council (TRC) must establish pierhead lines around all New Jersey islands prospectively, or whether the Council can set or modify a pierhead line in the context of reviewing an application for a tidelands license.

Respondent P.T. Jibsail Family Limited Partnership (Jibsail) owns a waterfront property on West Point Island. Petitioner Janine Morris Trust (JMT), owns waterfront property adjacent to Jibsail’s. In 2017, Jibsail received a permit from the Department of Environmental Protection (DEP) to build a dock extension and a ten-year tidelands license from the TRC. After the extension was built and found to be 1.7 feet south of the permitted location, Jibsail applied for a modified permit for the as-built dock, which was approved. In April 2019, Jibsail applied to the TRC for a modified tidelands license for the as-built dock extension.

JMT opposed Jibsail’s application, claiming the extension created navigational hazards and impacted JMT’s rights to use its own dock. At a public hearing, Jibsail explained that the extension was required by DEP subaquatic vegetation habitat rules and by licenses previously granted to neighboring properties to construct similar length docks. The TRC postponed its decision. In September 2022, the TRC approved the modified license. JMT appealed, contesting the TRC’s approval of the 2017 and 2022 tidelands licenses. The Appellate Division affirmed, finding the TRC’s decision was not arbitrary, capricious, or unreasonable. JMT petitioned for certification, arguing that Section 19 of the Tidelands Act requires the TRC to establish pierhead lines around islands prospectively on a “global and uniform basis.” The Court granted certification. 260 N.J. 91 (2025).

HELD: The TRC did not exceed its statutory authority in granting Jibsail’s 2017 or 2022 tidelands licenses because the plain language of the Tidelands Act authorizes the TRC to set or modify a pierhead line in the context of reviewing an application for a specific tidelands license, rather than requiring the TRC to establish pierhead lines around all New Jersey islands uniformly in advance. 1 1. The Tidelands Act governs the use of the State’s tidelands and creates the TRC as “the public body responsible for the stewardship” of tidelands, or riparian lands. N.J.S.A. 12:3-12.1. It is the responsibility of the TRC “to determine whether applications for the lease, license, or grant of riparian lands are in the public interest” and, if so, to “obtain the fair market value for the lease, license or grant.” Ibid. N.J.S.A. 12:3-19 and -20 together govern the TRC’s management of tidelands surrounding islands. Both were enacted on February 10, 1891. (pp. 12-15)

2. N.J.S.A. 12:3-19 currently provides that the TRC “shall, from time to time, fix and establish, around or in front of all islands, reefs and shoals situate in the tidal waters of this State, exterior lines . . . beyond which no pier . . . of any kind shall be made or maintained.” “From time to time” means “once in a while”; “occasionally.” Thus, rather than requiring the TRC to map pierhead lines around all islands “in the tidal waters of this State” immediately upon enactment, or by some date certain thereafter, the Legislature chose to allow the TRC to “fix and establish” pierhead lines “once in a while,” “occasionally,” or “now and then,” as the TRC saw fit. And rather than requiring the TRC to set pierhead lines all the way “around” each island in the State, the Legislature chose to permit the TRC to fix pierhead lines “around or in front of all islands.” The plain text of Section 19 thus does not mandate that the TRC establish one uniform pierhead line around each island; instead, the TRC can establish separate pierhead lines “in front of” separate parts of an island -- i.e., it can “fix and establish” a pierhead line in front of an individual property owner’s land. The requirement at the end of Section 19 to file a map showing the lines “so fixed and established” is most naturally read to apply only to pierhead lines placed in front of a riparian grant that existed before February 10, 1891. (pp. 15-19)

3. The Court’s interpretation is consistent with TRC practice since 1891. For almost 70 years, the TRC has relied on a series of decisions for support that it may establish or modify pierhead lines when reviewing an application for a specific license. The Court explains why JMT is mistaken that one of those decisions, Schultz v. Wilson, 44 N.J. Super. 591 (App. Div. 1957), is no longer good law. Over the past 135 years, the TRC has never undertaken to map comprehensive pierhead lines around all islands in the State. If the Legislature believed that was in violation of the Tidelands Act, it likely would have said so. The Court explains why reading Section 19 to permit the TRC to fix or modify a pierhead line in front of part of an island in the context of a particular license does not render “entire sections” of the Tidelands Act inoperative. (pp. 19-24)

AFFIRMED.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, PIERRE-LOUIS, FASCIALE, NORIEGA, and HOFFMAN join in JUSTICE WAINER APTER’s opinion. 2 SUPREME COURT OF NEW JERSEY A-35 September Term 2024 089547

In the Matter of P.T. Jibsail Family Limited Partnership Tidelands License Number 1515-06-0012.1 TDI 190001.

On certification to the Superior Court, Appellate Division.

Argued Decided October 21, 2025 March 18, 2026

Michael G. Sinkevich, Jr. argued the cause for appellant Janine Morris Trust (Lieberman Blecher & Sinkevich, and Mylod & Fitzgerald, attorneys; Michael G. Sinkevich, Jr., of counsel and on the briefs, and C. Michael Gan and Philip G. Mylod, on the briefs).

Amie C. Kalac argued the cause for respondent P.T. Jibsail Family Limited Partnership (Cullen and Dykman, attorneys; Amie C. Kalac and Neil Yoskin, of counsel and on the briefs).

Mark Collier, Deputy Attorney General, argued the cause for respondent New Jersey Department of Environmental Protection (Matthew J. Platkin, Attorney General, attorney; Sookie Bae-Park, Assistant Attorney General, of counsel, and Mark Collier, W. Conor Kennedy, and Jonathan Allen, Deputy Attorneys General, on the briefs).

Michele R. Donato submitted a brief on behalf of amicus curiae Save Barnegat Bay (Michele R. Donato, on the brief).

1 JUSTICE WAINER APTER delivered the opinion of the Court.

This case requires us to determine whether the Tidelands Resource

Council must establish pierhead lines around all New Jersey islands

prospectively, or whether the Council can set or modify a pierhead line in the

context of reviewing an application for a tidelands license.

Tidelands are lands that are covered by water at mean high tide. See

O’Neill v. State Highway Dep’t, 50 N.J. 307, 323-24 (1967). New Jersey

owns all tidelands up to three geographical miles off the coast. See 43 U.S.C

§§ 1301(a), 1311(a). The Tidelands Act authorizes the Tidelands Resource

Council (TRC) to grant a license, in exchange for a fee, to an individual who

wants to construct a dock on tidelands. N.J.S.A. 12:3-10, -12. It also

authorizes the TRC to “fix and establish” pierhead lines -- the line “beyond

which no pier, wharf, bulkhead, erection or permanent obstruction of any kind

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In the Matter of P.T. Jibsail Family Limited Partnership Tidelands License Number 1515-06-0012.1 TDI 190001, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-pt-jibsail-family-limited-partnership-tidelands-license-nj-2026.