J.H. v. Warren Hills Board of Education

CourtNew Jersey Superior Court Appellate Division
DecidedApril 28, 2025
DocketA-2896-23
StatusPublished

This text of J.H. v. Warren Hills Board of Education (J.H. v. Warren Hills Board of Education) 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. Warren Hills Board of Education, (N.J. Ct. App. 2025).

Opinion

RECORD IMPOUNDED

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2896-23

J.H., APPROVED FOR PUBLICATION April 28, 2025 Plaintiff-Respondent, APPELLATE DIVISION

v.

WARREN HILLS BOARD OF EDUCATION and WARREN HILLS JUNIOR HIGH SCHOOL,

Defendants-Appellants,

and

THE ESTATE OF F.M.,

Defendant.

Argued February 25, 2025 – Decided April 28, 2025

Before Judges Gilson, Firko, and Augostini.

On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Warren County, Docket No. L-0423-21.

Jerald J. Howarth argued the cause for appellants (Howarth & Associates, LLC, attorneys; Jerald J. Howarth, on the briefs). Jeffrey M. Russo argued the cause for respondent (Russo Law Offices, LLC, attorneys; Jeffrey M. Russo, on the brief).

Eric G. Kahn argued the cause for amicus curiae New Jersey Association for Justice (Javerbaum Wurgaft Hicks Kahn Wikstrom & Sinins, attorneys; Eric G. Kahn, of counsel and on the brief; Annabelle M. Steinhacker, on the brief).

Thomas J. Manzo argued the cause for amicus curiae New Jersey State Bar Association (William H. Mergner, Jr., President, of counsel and on the brief; Craig J. Hubert and Thomas J. Manzo, on the brief).

Hach Rose Schirripa & Cheverie, LLP, attorneys for amicus curiae Child USA (Hillary Mara Nappi, of counsel and on the brief).

The opinion of the court was delivered by

GILSON, P.J.A.D.

In 2019, the Legislature enacted two laws, which amended and

supplemented the statutes of limitations and procedural requirements for civil

actions alleging sexual abuse. See L. 2019, c. 120 (Chapter 120); L. 2019, c.

239 (Chapter 239). As part of those amendments, the Legislature eliminated the

notice requirement in the Tort Claims Act (TCA), N.J.S.A. 59:1-1 to 12-3, for

victims of sexual abuse. See Chapter 120, § 8 (codified at N.J.S.A. 59:8-3(b)).

The Legislature also expanded the type of persons and entities that can be liable

for sexual abuse by amending the Child Sexual Abuse Act (CSA Act), N.J.S.A.

A-2896-23 2 2A:61B-1, to eliminate the requirement that a passive abuser be "within the

household" of the victim. See Chapter 120, § 4.

This appeal presents two questions concerning the interpretations of the

2019 statutory amendments. First, whether the amendment to the notice

provision in the TCA, Chapter 120, § 8, applies to common law claims related

to allegations of sexual abuse of a minor. Second, whether the amendment

removing the "within the household" requirement from the CSA Act, Chapter

120, § 4, applies to cases filed after the December 1, 2019 effective date or only

to actions that accrued after the effective date.

We hold that the 2019 amendment eliminating the notice requirement in

the TCA applies to common law claims that are directly related to the sexual

abuse of a minor. We also hold that the 2019 amendment to the CSA Act, which

eliminated the "within the household" requirement, applies to any action filed

after December 1, 2019, and that it is not limited to claims that accrued after

December 1, 2019.

Accordingly, in this matter, we affirm a November 30, 2023 order denying

partial summary judgment to defendants Warren Hills Board of Education (the

Board) and Warren Hills Junior High School (the Junior High School). The

Board and the Junior High School had moved for partial summary judgment,

A-2896-23 3 arguing that plaintiff's common law claims should be dismissed because he did

not file a timely notice of claim under the TCA, and they were not subject to

liability under the CSA Act.1 We also affirm an April 11, 2024 order denying

the Board's and the Junior High School's motion for reconsideration.

I.

In November 2021, plaintiff sued the Board, the Junior High School, and

the Estate of F.M. Plaintiff alleged that F.M. had sexually abused him between

1976 and 1978, when plaintiff was a student at the Junior High School and F.M.

was employed as a custodian and wrestling coach at the school. F.M. died in

1995.

Plaintiff asserted claims under the CSA Act, the Law Against

Discrimination (LAD), N.J.S.A. 10:5-1 to -50, and common law claims of

negligence, including negligent hiring, retention, and supervision of F.M.

Plaintiff also asserted claims of gross negligence, intentional infliction of

emotional distress, and breach of fiduciary duty.

After conducting some discovery, the Board and the Junior High School

moved for partial summary judgment. They argued that plaintiff's common law

1 We use initials or "plaintiff" to protect plaintiff's privacy interests as an alleged victim of child sexual abuse. See R. 1:38-3(c)(9). A-2896-23 4 claims against them were barred by the TCA because plaintiff had not given

timely notice of those claims. They also argued that they were not passive

abusers under the CSA Act because they had not been a member of plaintiff's

household. In that regard, they contended that the 2019 amendment to the CSA

Act, which eliminated the "within the household" requirement, was intended to

be applied prospectively, and thus did not apply to plaintiff's claims, which had

accrued well before 2019. 2

After hearing argument, the trial court denied the motion for partial

summary judgment in an order entered on November 30, 2023. The court

supported that ruling with a written opinion. In its written opinion, however,

the trial court stated that it was dismissing the CSA Act claims.

The Board and the Junior High School moved for reconsideration. On

April 11, 2024, the trial court issued an order denying the motion for

reconsideration. In a written opinion, the trial court explained that its November

30, 2023 order was the correct ruling and that it had not intended to dismiss the

CSA Act claims.

2 The Board and Junior High School had also sought summary judgment to dismiss plaintiff's LAD claims but later withdrew that part of their motion. A-2896-23 5 We granted the Board's and the Junior High School's motion for leave to

appeal from both orders to resolve the two issues of statutory interpretation. We

also accelerated the appeal.

II.

The Board and Junior High School argue the trial court erred in denying

them partial summary judgment on two grounds. First, they contend that the

2019 amendment to the TCA only applies to plaintiff's CSA Act claims and does

not apply to his common law claims. So, they assert that because plaintiff did

not provide a timely notice of his common law claims under the TCA, they are

entitled to immunity from those claims. Second, the Board and Junior High

School assert that the 2019 amendment to the CSA Act, expanding passive

abuser liability, applies only to claims that accrue after the effective date of

Plaintiff disagrees with those interpretations and argues that the trial court

correctly denied the motion for partial summary judgment and reconsideration.

Plaintiff asserts that no TCA notice is required for common law claims if those

claims are directly related to a sexual assault. Additionally, plaintiff argues that

the "within the household" requirement is not applicable to any claim filed after

December 1, 2019, without regard to when the claim accrued.

A-2896-23 6 Three amici have filed briefs in support of plaintiff's positions. The amici

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