Jane Doe

CourtNew Jersey Superior Court Appellate Division
DecidedMay 1, 2026
DocketA-2439-24
StatusUnpublished

This text of Jane Doe (Jane Doe) 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
Jane Doe, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2439-24

JANE DOE (a minor child), and K.B.M. and S.B.M. (parents and guardians of Jane Doe),

Plaintiffs,

v.

PARAMUS BOARD OF EDUCATION,

Defendant-Respondent,

and

N.A. (minor child), I.A. (individually and as parent and guardian for minor child N.A.), and J.C. (individually and as parent and guardian for minor child N.A.),

Defendants-Appellants,

N.A. (minor child), I.A. (individually and as parent and guardian for minor child N.A.), and J.C. (individually and as parent and guardian for minor child N.A.),

Third-Party Plaintiffs,

BOROUGH OF PARAMUS, NEW JERSEY (a New Jersey Municipal Corporation), K.B.M. (individually), and S.B.M. (individually),

Third-Party Defendants. ______________________________

Submitted April 23, 2026 – Decided May 1, 2026

Before Judges Mawla, Marczyk, and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-5001-21.

Shapiro Croland Reiser Apfel & Di Iorio LLP, attorneys for appellants (Joshua M. Lurie and Adam P. Burns, on the briefs).

McGivney, Kluger, Clark & Intoccia, PC, attorneys for respondent Paramus Board of Education (Derrick A. Grant, of counsel and on the brief).

PER CURIAM

Appellants N.A. and his parents, I.A. and J.C., appeal from: a June 14,

2024 order granting respondent Paramus Board of Education summary judgment

and dismissing appellants' claims with prejudice; a July 19, 2024 order denying

A-2439-24 2 appellants' motion for reconsideration; and a February 28, 2025 order denying

appellants' motion for relief from the summary judgment order. We affirm.

This appeal arises from a lawsuit initially filed against appellants and

respondent by plaintiffs Jane Doe and her parents, alleging N.A. perpetrated

harassment, intimidation, and bullying (HIB) against Doe based on her race and

sex while they were middle school students. The parties resolved plaintiffs'

lawsuit, and plaintiffs are not part of this appeal. However, appellants asserted

crossclaims against respondent, alleging: violations of the New Jersey Law

Against Discrimination (LAD), N.J.S.A. 10:5-1 to -50; violations of the

Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12101-12213; and

negligence, vicarious liability, and respondeat superior claims based on N.A.'s

disability.

N.A. is diagnosed with Autism Spectrum Disorder (mild), Attention

Deficit Hyperactivity Disorder (ADHD), Generalized Anxiety Disorder, and

Post-Traumatic Stress Disorder. He has an Individualized Education Program

(IEP) with the classification of Emotion Regulation Impairment. As a result, he

is qualified for various school-based services under the Individuals with

Disabilities Education Act (IDEA), 20 U.S.C. § 1415.

A-2439-24 3 Appellants' crossclaims alleged respondent failed to take any action

against Doe—despite the fact N.A. and his mother made complaints against Doe

over several years—and instead retaliated against N.A. The LAD and ADA

claims alleged respondent: discriminated against N.A. based on his ADHD;

failed to adequately investigate HIB complaints made by and against N.A.;

retaliated against N.A. by failing to find his actions were manifestations of his

disability; and unfairly disciplined him. Appellants claimed respondent was

negligent for: breaching its duties under the Anti-Bullying Bill of Rights Act

(ABR), N.J.S.A. 18A:37-13.2 to -37; failing to take appropriate action when

appellants made complaints against Doe; conducting inadequate investigations

and substantiating claims made by Doe against N.A. without complying with the

ABR; and retaliating against N.A. for HIB complaints made by and against him

involving Doe. The crossclaims also asserted respondent was vicariously liable

under the doctrine of respondeat superior for its employees' discrimination and

negligence.

The facts showed Doe filed six claims against N.A. for HIB and

respondent's anti-bullying specialist investigated and substantiated HIB based

upon Doe's race and gender. Appellants did not appeal this finding. The

specialist also conducted at least two HIB investigations where N.A. accused

A-2439-24 4 Doe of being the aggressor but found Doe's alleged actions were not motivated

by an actual or perceived characteristic of N.A. and, instead, were based on a

history of conflict between both students.

Respondent's anti-bullying specialist stated she considers whether a

student's behavior manifested from their disability when conducting HIB

investigations. The school held IEP meetings after N.A.'s HIB incidents.

N.A.'s mother requested he be transferred out of Doe's classes after the

first HIB investigation, and she eventually had him transferred to a different

middle school in the district. N.A. never reported he was bullied to his teachers

or school administrators. He never spoke about his disability with Doe. N.A.

recalled being suspended one day for fighting at his first middle school. He was

later suspended for two days for fighting at the middle school to which his

mother had arranged his transfer. The fighting incidents did not involve Doe.

In January 2023, while this matter was pending, N.A. got into a physical

altercation at his high school, again not involving Doe. Upon his return to

school after serving a short suspension for a separate incident, N.A. told his

mother he was reluctant to go back because another student, X.Y., had

threatened him. That day, an altercation ensued during lunch. A video showed

A-2439-24 5 N.A. approaching X.Y., X.Y. saying something to N.A., and N.A. punching

X.Y. several times before school staff could intervene.

In February 2023, the child study team (CST) conducted a manifestation

determination review of N.A.'s actions vis-à-vis X.Y. If the CST had determined

N.A.'s behavior was a manifestation of his disability, it would have conducted a

functional behavioral assessment and implemented a behavioral intervention

plan. However, it concluded N.A.'s actions were premeditated and spontaneous,

thus not a manifestation of his disability. This permitted respondent to

discipline N.A. the same way it would have, had he not been receiving special

education, resulting in his indefinite suspension.

N.A.'s mother claimed the discipline imposed against her son after his

altercations was in retaliation for Doe's and appellants' lawsuits. However, she

had no evidence of retaliation. N.A.'s father claimed respondent unfairly

disciplined N.A. after Doe filed her lawsuit but never reported N.A. was bullied.

Doe stated N.A. told her about his ADHD diagnosis in the fifth grade, but

they did not speak about it again. She never made comments about his ADHD

or his background in any respect.

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