James Elder v. Crest Union, LLC

CourtNew Jersey Superior Court Appellate Division
DecidedJuly 8, 2026
DocketA-4186-24
StatusUnpublished

This text of James Elder v. Crest Union, LLC (James Elder v. Crest Union, LLC) 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 Elder v. Crest Union, LLC, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-4186-24

JAMES ELDER and SARAH ELDER,

Plaintiffs-Respondents,

v.

CREST UNION, LLC, CREST UNION MANAGEMENT ASSOCIATES, LLC, and MITCHELL HARLEY,

Defendants-Appellants. __________________________

Submitted December 15, 2025 – Decided July 8, 2026

Before Judges Natali and Bergman.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-3244-24.

Mark S. Carter, attorney for appellants.

Joel & Joel, LLP, attorneys for respondents (Richard A. Joel, Jr., on the brief).

PER CURIAM Defendants Crest Union, LLC, Crest Union Management Associates,

LLC, and Mitchell Harley appeal from an August 21, 2025 order denying their

motion to dismiss plaintiffs James and Sarah Elder's 1 complaint and to compel

arbitration. Based on our de novo review, we conclude that the arbitration clause

is unenforceable and accordingly affirm.

I.

The parties entered two contracts in May 2022 regarding the renovation

of the plaintiffs' home. The first consisted of three and a half pages with a two-

page rider titled "General Conditions." It was prepared by Crest Union, and

signed on its behalf by Harley as President, and executed by the plaintiffs on

May 6th. The second contract, prepared by plaintiffs "to protect [them] and the

home" was signed on May 16th by plaintiffs and again by Crest Union and

Harley. It consisted of five pages, also with a rider called "General Conditions."

Both contracts included the identical arbitration provision in paragraph eight of

the "General Conditions" section, which addressed mediation and arbitration

procedures for dispute resolution. It provided:

If a dispute arising out of or relates to this Contract, or the breach thereof, and if the dispute cannot be settled through negotiation, the parties agree first to try in good

1 Because plaintiffs share the same surname, we refer to them at times by their first names for clarity, and intend no disrespect in doing so. A-4186-24 2 faith to settle the dispute by mediation administered by the American Arbitration Association under its commercial Mediation Procedures before resorting to arbitration or some other dispute resolution procedure. If they do not reach such solution within 60 days, then, upon notice by either party to the other, all disputes, claims, questions, or differences shall be finally settled by arbitration administered by the American Arbitration Association in accordance with the provisions of its commercial Arbitration Rules.2

Plaintiffs contended defendants' performance under the contracts was

untimely and defective and sued them in June 2024. In the complaint, plaintiffs

asserted claims for breach of contract, negligence, fraud, and violation of the

Consumer Fraud Act. Instead of immediately moving to dismiss the complaint

and compel arbitration, defendants instead filed a timely answer, denied all

material allegations, asserted among other defenses that the matter was subject

to arbitration, and also filed a counterclaim sounding in breach of contract.

Defendants first moved to dismiss the complaint and compel arbitration

in April 2025, approximately ten months later. After considering the parties'

written submissions and oral arguments, the trial court denied the motion by

order dated May 19, 2025 and explained its decision in a written statement of

2 It does not appear either party complied with the requirements of the arbitration clause that obligated them to negotiate first, and then attempt in good faith to resolve any dispute by mediation administered by the American Arbitration Association. A-4186-24 3 reasons in which it concluded that the arbitration clause was unenforceable

under Atalese v. U.S. Legal Services Group, L.P., 219 N.J. 430 (2014), because

it did not clearly inform the plaintiffs they were waiving their right to pursue

their claims in court or to a jury trial.

The court also expressed reservations regarding whether all defendants

could be bound by the arbitration provision, given the identities of the

signatories to the contract. On this point, it noted that Crest Union Management

Associates was not named in the contract and thus it did not have the right to

arbitrate plaintiffs' claims, since it was not a party to the agreement containing

the arbitration clause. The court further observed that the complaint was unclear

as to whether Harley was being sued in his individual capacity or solely as

President of Crest Union. The court explained that to the extent Harley was

being sued individually, he would not be entitled to enforce the arbitration

provision because he seemingly executed the contract only in his corporate

capacity.

Approximately three months later in late July, defendants renewed their

motion to compel by filing a near identical application, except that they relied,

in part, on portions of the deposition testimony of Sarah Elder. According to

defendants, in that deposition, Sarah acknowledged that by proceeding to

A-4186-24 4 arbitration, she understood she was relinquishing her right to appear in court and

have the matter resolved at trial by jury. The court again denied defendants'

application and explained its decision in an August 15, 2025 oral decision.

The court considered defendants' application as a motion for

reconsideration and noted the only new evidence offered was Sarah Elder's

partial deposition testimony.3 The court found Sarah's deposition testimony

irrelevant because under Atalese, the enforceability of an arbitration clause is

determined by the language of the contract itself, not by the parties' subjective

understanding or after-the-fact interpretation. On this point, the court

specifically stated that Atalese required courts to examine and consider the

"relevant contractual language" and to "determine whether mutual assent has

been achieved."

Considering the arbitration provision in that context, the court noted that

it did not mention, even in general terms, that the parties intended to waive their

right to a jury trial or to pursue claims in court, and thus the provision failed to

3 We agree with the court's characterization of the motion. We also note that defendants' notice of appeal does not list the court's May 19th order as an order to which they appeal. Notwithstanding, as discussed supra, we have applied a de novo rather than an abuse of discretion standard of review as the issue presented is a legal one, and reject defendants' arguments under either standard of review. A-4186-24 5 satisfy Atalese's most basic requirement. The court also emphasized that

Atalese hardly imposed a difficult burden on defendants, as all they needed to

do was to simply include a sentence in the contract that stated, "[b]y agreeing to

arbitration, you will waive your right . . . to have this matter resolved in court

and/or by a trial by jury."

The court further explained its reasoning in an August 21, 2025 written

decision in which it reemphasized the points it expressed orally, and further

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James Elder v. Crest Union, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-elder-v-crest-union-llc-njsuperctappdiv-2026.