James Andriani v. Hudson County Schools of Technology

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 7, 2024
DocketA-1704-22
StatusUnpublished

This text of James Andriani v. Hudson County Schools of Technology (James Andriani v. Hudson County Schools of Technology) 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
James Andriani v. Hudson County Schools of Technology, (N.J. Ct. App. 2024).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1704-22

JAMES ANDRIANI,

Plaintiff-Appellant,

v.

HUDSON COUNTY SCHOOLS OF TECHNOLOGY,

Defendant-Respondent. ____________________________

Submitted January 29, 2024 – Decided February 7, 2024

Before Judges Sabatino, Mawla, and Vinci.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Docket No. L-3335-22.

The Toscano Law Firm, LLC, attorneys for appellant (Patrick P. Toscano, Jr, of counsel and on the briefs; Matthew J. Toscano, on the briefs).

Lenox, Socey, Formidoni, Giordano, Lang, Carrigg & Casey, LLC, attorneys for respondent (Michael A. Pattanite Jr., of counsel and on the brief).

PER CURIAM Plaintiff James Andriani, a former administrator employed by defendant

Hudson County Schools of Technology ("HCST"), appeals the trial court's

February 10, 2023 dismissal of his constructive discharge lawsuit. The court

concluded that plaintiff filed his complaint after the applicable statutes of

limitations had expired. We agree with the court's application of the time bar,

and consequently affirm.

We briefly summarize the factual background, the details of which are

well known to the parties. The HCST has a program known as "accelerated

retirement" or "terminal leave." The program enables eligible employees

nearing retirement age to stop working and enter a path to full retirement.

Plaintiff chose to take terminal leave in December 2019. He alleges that,

starting in early 2019, he was wrongfully pressured to do so by the HCST

business administrator, in violation of the Law Against Discrimination, N.J.S.A.

10:5-1 to -50 ("LAD"), and the Conscientious Employee Protection Act,

N.J.S.A. 34:19-1 to -14 ("CEPA"). Plaintiff further alleges his work

environment leading up to December 2019 had become hostile for

discriminatory and retaliatory reasons. The HCST kept open plaintiff's position

for about a year, when the HCST eventually filled it by promoting a younger

person.

A-1704-22 2 Plaintiff filed his complaint in the Law Division in October 2022, two

years and ten months after he had begun his terminal leave in December 2019.

The HCST moved to dismiss the complaint for failure to state a viable claim

within the statutes of limitations. Plaintiff argued to the trial court, as he does

here, that his causes of action did not accrue until October 1, 2022, when his

terminal leave ended, and he formally retired from his employment.

The legal principles that guide our analysis are well established. We

review the trial court's application of those principles de novo. Save Camden

Pub. Schs. v. Camden City Bd. of Educ., 454 N.J. Super. 478, 487 (App. Div.

2018) (noting that "whether a cause of action is barred by a statute of limitations

is a question of law that we review de novo").

The LAD prohibits unlawful discrimination by employers because of an

individual's age, among other protected categories. N.J.S.A. 10:5-12. The

statute of limitations for a LAD claim is two years. Montells v. Haynes, 133

N.J. 282, 292-96 (1993). Claims under the LAD filed more than two years after

the alleged discriminatory actions are to be dismissed. Roa v. Roa, 200 N.J.

555, 566 (2010).

"Determining when the limitation period begins to run depends on when

the cause of action accrued, which in turn is affected by the type of conduct a

A-1704-22 3 plaintiff alleges to have violated the LAD." Alexander v. Seton Hall Univ., 204

N.J. 219, 228 (2010). Generally, a discrete act of discrimination or retaliation

is readily determined as "occur[ing] on the day that it 'happen[s].'" Roa, 200

N.J. at 567 (second alteration in original) (quoting Nat'l R.R. Passenger Corp.

v. Morgan, 536 U.S. 101, 110 (2002)). "[W]hen the complained-of conduct

constitutes 'a series of separate acts that collectively constitute one unlawful

employment practice[,]' the entire claim may be timely if filed within two years

of 'the date on which the last component act occurred.'" Alexander, 204 N.J. at

229 (second alteration in original) (quoting Roa, 200 N.J. at 567).

In the present case, plaintiff claims he was forced to take terminal leave

in December 2019 because of coercive and discriminatory conduct by his

employer. Because he was not actually terminated at that time, his claim

represents a claim of constructive discharge.

Constructive discharge under the LAD generally "occurs when an

'employer knowingly permit[s] conditions of discrimination in employment so

intolerable that a reasonable person subject to them would resign.'" Shepherd

v. Hunterdon Developmental Ctr., 174 N.J. 1, 27-28 (2002) (quoting Muench v.

Twp. of Haddon, 255 N.J. Super. 288, 302 (App. Div. 1992) (internal citations

omitted)). See also Donelson v. DuPont Chambers Works, 206 N.J. 243, 257

A-1704-22 4 (2011) (citing Shepherd, 174 N.J. at 28).

Similar principles apply to plaintiff's claims under CEPA. The statute of

limitations under CEPA is shorter than under the LAD. A complainant must

bring a claim under CEPA with one year of the alleged retaliatory employment

action. N.J.S.A. 34:19-5. If a claim stems from a wrongful actual termination,

the "employee's cause of action under CEPA accrues on the date of actual

discharge." Alderiso v. Med. Ctr. of Ocean Cnty. Inc., 167 N.J. 191, 194 (2001).

"[I]n an actual termination situation, the retaliatory action which starts the

running of the period of limitations is the separation from work." Daniels v.

Mutual Life Ins. Co., 340 N.J. Super. 11, 17 (App. Div. 2001).

By comparison, a constructive discharge under CEPA "occurs when the

employer has imposed upon an employee working conditions 'so intolerable that

a reasonable person subject to them would resign.'" Ibid. (quoting Muench, 255

N.J. Super. at 302). "In a constructive discharge situation, the retaliatory action

is the creation of intolerable conditions which a reasonable employee cannot

accept." Id. at 17-18. The critical date of accrual is the date on which the

plaintiff felt compelled to stop working. Id. at 17. "The harm has been done

when the employee feels compelled to resign." Ibid.

Plaintiff's pleadings make clear that the day he felt forced to take terminal

A-1704-22 5 leave was the day his retirement path began, and the day he no longer intended

to work for HCST. He theorizes that he could have changed his mind about

retirement during his terminal leave. However, that possibility never

materialized. Moreover, defendant's allegedly coercive and unlawful conduct

that compelled plaintiff to go on terminal leave occurred on or before December

1, 2019.

We reject plaintiff's alternative contention that, at the very earliest, his

cause of action did not accrue until about a year after his December 2019

departure, when the HCST filled his position with a younger employee. That

argument fails.

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