Jane Doe v. Zeta Psi Fraternity, Inc.

CourtNew Jersey Superior Court Appellate Division
DecidedApril 29, 2025
DocketA-1613-23
StatusUnpublished

This text of Jane Doe v. Zeta Psi Fraternity, Inc. (Jane Doe v. Zeta Psi Fraternity, Inc.) 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 v. Zeta Psi Fraternity, Inc., (N.J. Ct. App. 2025).

Opinion

RECORD IMPOUNDED

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1613-23

JANE DOE,

Plaintiff-Appellant,

v.

ZETA PSI FRATERNITY, INC.,

Defendant-Respondent,

and

DELTA CHAPTER OF ZETA PSI FRATERNITY, ALUMNI ASSOCIATION OF THE DELTA CHAPTER OF ZETA PSI FRATERNITY OF NORTH AMERICA, INC.,

Defendants. ________________________________

Submitted January 23, 2025 – Decided April 29, 2025

Before Judges Marczyk, Paganelli and Torregrossa- O'Connor.

On appeal from the Superior Court of New Jersey, Law Division, Middlesex County, Docket No. L-6507-19. Brian D. Kent (Laffey Bucci & Kent, LLP) and M. Stewart Ryan (Laffey Bucci & Kent, LLP), attorneys for appellant.

Zarwin, Baum, DeVito, Kaplan, Schaer & Toddy, PC, attorneys for respondent (Timothy P. Mullin, on the brief).

PER CURIAM

Plaintiff Jane Doe appeals from the trial court order of April 28, 2023, that

granted defendant Zeta Psi Fraternity, Inc. (Zeta Psi) summary judgment and

dismissed her complaint with prejudice. The April order granted

reconsideration of a trial court order of March 2, 2023, that had denied Zeta Psi

summary judgment.1 Because there were no material facts in dispute and the

trial court correctly applied the law, we affirm.

I.

Zeta Psi is an international men's fraternal organization. Delta was

recognized by Zeta Psi and Rutgers University (Rutgers) as a local chapter of

Zeta Psi on Rutgers's New Brunswick, New Jersey campus. The Alumni

1 Defendant Delta Chapter of Zeta Psi Fraternity (Delta) was granted summary judgment in the March order. Plaintiff has not appealed that order. While the appeal was pending, plaintiff filed a stipulation of dismissal as to defendant Alumni Association of the Delta Chapter of Zeta Psi Fraternity of North America, Inc. (Alumni Association).

A-1613-23 2 Association "is an independent self-governing entity." According to the Alumni

Association's bylaws, its purpose, in part, is to "afford home, educational, social

and recreative advantages to any students at Rutgers . . ., who may be members

of the Delta Chapter." The Alumni Association owned a house in New

Brunswick. The house served as a fraternity house for the Delta Chapter.

In February 2014, Frank DiLeo, on behalf of the Alumni Association,

suspended Delta's charter. In the letter of suspension, DiLeo explained the

suspension was necessary because all other "avenues available to change . . .

behavior" of the members had not worked. Further, the letter advised that "[i]t

ha[d] been made very clear that no social activities [we]re allowed at the house

going forward and that [Delta] as an organization ha[d] ceased operations."

The suspension was imposed for five years. The goal was to "allow any

initiated undergraduate to matriculate," and have Delta start anew with

reinstatement in the Spring of 2019.

During the period of suspension, the Alumni Association leased the house

to another fraternity for approximately one year, and entered into individual

leases with other tenants who were members of other fraternities or who had no

fraternity affiliation at all.

A-1613-23 3 In August 2016, Timothy Little, Secretary of the Board of Trustees to the

Alumni Association, wrote a letter to Lauk Walton, Executive Director of Zeta

Psi, following their telephone conference, to "formalize" the Alumni

Association's request to accelerate Zeta Psi's "time line to recolonize . . . Delta."

Little explained the Alumni Association "need[ed] to verify that [Zeta Psi]

w[ould] consider reinstatement of [the] Charter." Little noted "[a]lcohol use in

[the house could ]not be tolerated" and "request[ed] the ability to start up in

January of 2017."

In November 2016, following a meeting between the Alumni Association

and Zeta Psi, Little again wrote to Walton. The letter was an attempt to

summarize their discussion and stated: Delta's suspension would remain until

the Spring Semester of 2018; but as early as January 2017 and through 2017, the

Alumni Association would be permitted to initiate associates. Little requested

that Walton "confirm that the summary . . . [wa]s accurate and acceptable."

On December 6, 2016, Walton, in a group email, stated he had met with

"junior staff" from Rutgers University Fraternity and Sorority Affairs (RUFSA)

regarding a "petition to return to campus." He noted, as Delta "start[ed] down

the path of this reactivation, it w[ould] be imperative that there are no risk

management slip ups or . . . linkage back to the old group."

A-1613-23 4 In addition, Walton stated he "would be reluctant to begin initiating any

young men to be future actives without the express approval of Zeta Psi . . .

th[at wa]s not an action [he] ha[d] the authority to approve."

In December 2016, Little again wrote a letter to Walton regarding Delta's

reinstatement at Rutgers. The letter advised it was "critical to . . . [Delta's]

reinstatement efforts that all efforts are made so that [Delta has] a fully

functioning active chapter by 2018, and not delay to 2019." Therefore, with the

"consent" of Zeta Psi, the Alumni Association was "initiating . . . candidates on

January 10, 2017, and . . . additional [candidates] in May and the following

December."

Further, Little advised that "the mandates set out in the Zeta Psi . . . Risk

Management [policies] are being taught and are required to be followed

precisely. We are committed to becoming a model chapter fully conforming to

the platforms and standards of the future . . . including the mandate to be alcohol

free."

In DiLeo's deposition, he testified that the January 10 initiation went

forward. He stated that individuals "were initiated into Zeta Psi by the Alumni

Association." Nonetheless, he stated, the initiation did not follow the "same

process" or "rituals" that Zeta Psi would use. He noted there was no: (1)

A-1613-23 5 documentation; (2) payment of dues; or (3) pin or book. He stated that neither

he nor the Alumni Association ever initiated anyone in this "fashion" before.

He stated that he did not notify Walton or Zeta Psi about the initiation

afterwards.

In late January 2017, Zeta Psi held an executive committee meeting. The

minutes of the meeting reflect that Delta's request "to initiate a small group of

brothers in anticipation of their 'impending' reactivation" and to "adjust the

rechartering date to Spring 2018," was denied.

Following the executive committee meeting, Walton emailed DiLeo and

advised "the timeline for the re-activation of . . . Delta . . . remain[ed] unchanged

with a target date of initiating new members and re-activating the chapter during

the 2019 Spring Semester."

In February 2017, Bhavin Hirpara and Mena Silver executed separate

leases with the Alumni Association. They picked each other as roommates. In

his deposition, Silver testified that when he executed the lease, he was not a

member of a fraternity and never became a member of a fraternity. He

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Massachi v. AHL Services, Inc.
935 A.2d 769 (New Jersey Superior Court App Division, 2007)
Hopkins v. Fox & Lazo Realtors
625 A.2d 1110 (Supreme Court of New Jersey, 1993)
Manalapan Realty v. Township Committee of the Township of Manalapan
658 A.2d 1230 (Supreme Court of New Jersey, 1995)
Mary Cheng Lin Wang v. Allstate Insurance
592 A.2d 527 (Supreme Court of New Jersey, 1991)
Wilson v. City of Jersey City
39 A.3d 177 (Supreme Court of New Jersey, 2012)
Fackelman v. Lac D'Amiante Du Quebec
942 A.2d 127 (New Jersey Superior Court App Division, 2008)
Gonzalez v. Safe & Sound Security Corp.
881 A.2d 719 (Supreme Court of New Jersey, 2005)
Manahawkin Convalescent v. Frances O'neill (071033)
85 A.3d 947 (Supreme Court of New Jersey, 2014)
Felix Peguero v. Tau Kappa Epsilon Local Chapter, Tau Kappa
106 A.3d 565 (New Jersey Superior Court App Division, 2015)
Fernandes v. Dar Development Co. (073001)
119 A.3d 878 (Supreme Court of New Jersey, 2015)
DepoLink Court Reporting & Litigation Support Services v. Rochman
64 A.3d 579 (New Jersey Superior Court App Division, 2013)
Davis v. Devereux Foundation
37 A.3d 469 (Supreme Court of New Jersey, 2012)
Nicholas v. Mynster
64 A.3d 536 (Supreme Court of New Jersey, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Jane Doe v. Zeta Psi Fraternity, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jane-doe-v-zeta-psi-fraternity-inc-njsuperctappdiv-2025.