J.H. v. the Lawrenceville School

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 28, 2026
DocketA-3846-24
StatusUnpublished

This text of J.H. v. the Lawrenceville School (J.H. v. the Lawrenceville School) 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
J.H. v. the Lawrenceville School, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3846-24

J.H.,

Plaintiff-Respondent,

v.

THE LAWRENCEVILLE SCHOOL, 2500 MAIN STREET, LAWRENCEVILLE, NJ 08648,

Defendant-Appellant. ____________________________

Argued January 8, 2026 – Decided January 28, 2026

Before Judges Mawla, Marczyk, and Bishop- Thompson.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County, Docket No. L-0992-25.

Brendan N. Gooley (Carlton Fields, PA) of the Connecticut Bar, admitted pro hac vice, argued the cause for appellant (Carlton Fields, PA, and Brendan N. Gooley, attorneys; Jorkeell Echeverria, James M. Sconzo, and Brendan N. Gooley, of counsel and on the brief). Corrie Woods (Kline & Specter, PC) of the Pennsylvania, West Virginia, United States District Court for the Western District of Pennsylvania, United States Court of Appeals for the Third Circuit, and United States Court of Appeals for the District of Columbia Circuit bars, admitted pro hac vice, argued the cause for respondent (Kline & Specter, PC, and Corrie Woods, attorneys; Charles L. Becker, Lorraine H. Donnelly, Ruxandra M. Laidacker, and Corrie Woods, on the brief).

PER CURIAM

We granted defendant The Lawrenceville School leave to appeal from a

July 8, 2025 order denying its motion to dismiss and compel arbitration of

plaintiff J.H.'s claims arising from a 2019 sexual assault committed by one of

the school's former employees. Having considered the record and the applicable

legal principles, we reverse in part and affirm as modified in part for the reasons

expressed in this opinion.

In 2019, J.H. was a freshman boarding student at the school when the

sexual assault occurred. The school employee was subsequently charged with

sexually assaulting J.H. and another student, and showing pornography to and

having a sexually explicit conversation with a third student. The employee

pleaded guilty to three counts of endangering the welfare of a child.

J.H. continued to attend the school following the assault. Each year, the

school sent a re-enrollment agreement to J.H.'s parent, which they would execute

A-3846-24 2 to enroll him for the subsequent school year. On March 1, 2022, J.H.'s father

executed a re-enrollment agreement for J.H.'s senior year, the 2022-2023 school

year. In May 2025, J.H. filed a four-count complaint against the school alleging:

violation of the Child Sex Abuse Act (CSAA), N.J.S.A. 2A:61B-1; negligence

and gross negligence; negligent hiring, retention, and supervision; and vicarious

liability for assault and battery.

Counsel for the school advised J.H.'s counsel his claims were subject to

arbitration pursuant to the arbitration provision in the 2022-2023 re-enrollment

agreement and demanded withdrawal of the complaint and that the matter

proceed to arbitration. Counsel for J.H. requested the school provide copies of

the enrollment agreements for each year J.H. attended the school because only

the 2022-2023 agreement had been provided. The school's counsel responded

the prior agreements were irrelevant because the 2022-2023 agreement

controlled as it contained a merger clause.

The school moved to compel arbitration pursuant to the 2022-2023

agreement. In opposition, J.H.'s father certified: the school never asked him to

waive his right to a jury trial for the 2019 sexual assault; he never intended to

waive the right to a jury trial; the school never explained there was an arbitration

agreement embedded in the 2022-2023 agreement; and the agreement, which

A-3846-24 3 governed the 2022-2023 school year, did not apply to claims, which arose prior

to that school year.

At oral argument, the school's counsel urged the motion judge to read the

entire agreement, which included an integration clause stipulating it superseded

all prior agreements and therefore controlled the relationship between the

parties. The school's counsel noted J.H. argued the Ending Forced Arbitration

of Sexual Assault and Harassment Act of 2021 (EFAA), 9 U.S.C. §§ 401-02,

barred arbitration of his claims. Counsel argued the EFAA was not persuasive

authority because the "[t]he Legislature had the opportunity to address the

EFA[A for claims like J.H.'s] and didn't. . . . In contrast, [the Legislature] did

address it in the context of [the New Jersey Law Against Discrimination, (LAD)

N.J.S.A. 10:5-1 to -50] claims . . . ."

J.H.'s counsel argued the arbitration agreement was unenforceable

because there was no mutual assent to arbitrate the 2019 dispute. The 2022-

2023 re-enrollment agreement was unambiguous and clear it applied only to that

school year. The parties' dispute arose in 2019.

The motion judge found there was "clearly no meeting of the minds that

signing the 2022[-]2023 . . . re-enrollment agreement would have the legal effect

of waiving [J.H.'s] right to [a] jury trial for a sexual assault dispute that arose in

A-3846-24 4 2019." The provision of the agreement, which denoted it only applied to the

2022-2023 academic year, reads as follows: "This Enrollment Agreement

("Agreement") is for the 2022-2023 academic year only. This Agreement is

contingent upon the Student's successful completion of the 2021-2022 academic

year in good academic, disciplinary, and financial standing, as determined by

the School in its sole discretion." The judge found the first sentence was not

confusing and the second sentence did not modify the first.

In relevant part, the arbitration integration provisions read as follows:

19) Applicable Law, Jurisdiction, Arbitration, Jury Waiver, Severability

This Agreement, and all rights and obligations provided for herein, will be governed by the laws of the State of New Jersey, without regard to conflict of law principles. The exclusive jurisdiction and venue for any dispute or claim arising out of or related to this Agreement, the relationship created by this Agreement, or the Student's enrollment at or withdrawal or dismissal from the School, such as claims for contract, tort (including claims for negligence due to personal injury or death to the student) or statute (including, without limitation, claims for harassment, discrimination or failure to make a reasonable accommodation under the [LAD]), shall be determined by arbitration in Lawrence Township, New Jersey, before a single arbitrator that the parties select.

By signing this agreement, I am agreeing not only to arbitrate all of my claims and disputes against the School but I am also agreeing to arbitrate all of the

A-3846-24 5 claims and disputes the Student may have against the School.

I understand and agree that arbitration is my sole remedy for any dispute or claim arising out of or related to this Agreement, and that I am waiving my right to sue and to have my claims adjudicated in a court of law, including by a jury. I also understand and agree that the decision of the arbitrator shall be final and binding.

....

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

Related

Doctor's Associates, Inc. v. Casarotto
517 U.S. 681 (Supreme Court, 1996)
Michael E. Hirsch v. Amper Financial Services, LLC (070751)
71 A.3d 849 (Supreme Court of New Jersey, 2013)
Hardwicke v. American Boychoir School
902 A.2d 900 (Supreme Court of New Jersey, 2006)
Martindale v. Sandvik, Inc.
800 A.2d 872 (Supreme Court of New Jersey, 2002)
Alfano v. BDO Seidman, LLP
925 A.2d 22 (New Jersey Superior Court App Division, 2007)
Moreira Constr. Co., Inc. v. Wayne Tp.
238 A.2d 185 (New Jersey Superior Court App Division, 1968)
J. Baranello & Sons, Inc. v. City of Paterson
403 A.2d 919 (New Jersey Superior Court App Division, 1979)
State v. Lisa
919 A.2d 145 (New Jersey Superior Court App Division, 2007)
Coast v. WITHUM SMITH & BROWN
995 A.2d 300 (New Jersey Superior Court App Division, 2010)
Do-Wop Corp. v. City of Rahway
773 A.2d 706 (Supreme Court of New Jersey, 2001)
Garfinkel v. Morristown Obstetrics & Gynecology Associates, P.A.
773 A.2d 665 (Supreme Court of New Jersey, 2001)
Fawzy v. Fawzy
973 A.2d 347 (Supreme Court of New Jersey, 2009)
Werner Industries, Inc. v. First State Insurance
548 A.2d 188 (Supreme Court of New Jersey, 1988)
Nieder v. Royal Indemnity Insurance
300 A.2d 142 (Supreme Court of New Jersey, 2004)
Muhammad v. County Bank of Rehoboth Beach, Delaware
912 A.2d 88 (Supreme Court of New Jersey, 2006)
ZORBA CONTRACTORS v. Housing Auth.
660 A.2d 550 (New Jersey Superior Court App Division, 1995)
Kieffer v. Best Buy
14 A.3d 737 (Supreme Court of New Jersey, 2011)
Patricia Atalese v. U.S. Legal Services Group, L.P. (072314)
99 A.3d 306 (Supreme Court of New Jersey, 2014)
Wurth v. Ideal Mutual Insurance
518 N.E.2d 607 (Ohio Court of Appeals, 1987)
NAACP of Camden County East v. Foulke Management Corp.
24 A.3d 777 (New Jersey Superior Court App Division, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
J.H. v. the Lawrenceville School, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jh-v-the-lawrenceville-school-njsuperctappdiv-2026.