John Loughrey v. County of Monmouth

New Jersey Superior Court Appellate Division·Decided August 5, 2026·No. A-3602-24·Unpublished

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-3602-24

JOHN LOUGHREY,

Plaintiff-Appellant,

v.

COUNTY OF MONMOUTH, TERI O'CONNOR, Monmouth County Administrator, and MICHAEL D. FITZGERALD, Monmouth County Counsel,

Defendants-Respondents. _____________________________

Argued June 3, 2026 – Decided August 5, 2026

Before Judges Gooden Brown, Rose and Torregrossa- O'Connor.

On appeal from the Superior Court of New Jersey, Law Division, Monmouth County, Docket No. L-1670-24.

John Loughrey, appellant, argued the cause on appellant's behalf.

Russell Macnow argued the cause for respondents (Russell Macnow, LLC, attorneys; Russell Macnow, on the brief).

Plaintiff John Loughrey appeals from the May 30, 2025 Law Division

order granting summary judgment in favor of defendants Monmouth County (the

County), Monmouth County Administrator Teri O'Connor, and Monmouth

County Counsel Michael D. Fitzgerald (collectively, defendants), thereby

dismissing plaintiff's complaint alleging breach of contract against defendants

for denying plaintiff lifetime no-cost health benefits, and the July 3, 2025 order

denying reconsideration and recusal.1 He also challenges the trial court's finding

that certain communications between O'Connor and Fitzgerald were privileged

and therefore not discoverable.

On de novo review, we consider whether, within the meaning of a

controlling Monmouth County resolution governing employee health benefits

1 Although we recognize plaintiff's notice of appeal indicates he challenges the court's denial of his motions for reconsideration and recusal, plaintiff's merits brief contains no arguments specifically related to the motions and notes only that "the issues from [the reconsideration and recusal] hearing are not the subject of this appeal." See Midland Funding, LLC v. Thiel, 446 N.J. Super. 537, 542 n.1 (App. Div. 2016) (when appellant's notice of appeal lists issues later "not briefed on appeal," the Appellate Division "considers [the] appeal from those [issues] abandoned . . . [and] waived"). Consequently, and because we determine the trial court properly granted summary judgment in defendants' favor, we need not further address the reconsideration or recusal decisions, as plaintiff conceded he abandoned on appeal any additional challenges to the reconsideration and recusal decision. A-3602-24 2 upon retirement, see Monmouth County, N.J., Bd. of Chosen Freeholders Res.

94-267 (Apr. 14, 1994), 2 plaintiff, a retired assistant county prosecutor, was

"hired" before July 1, 1994—the cutoff date for eligibility for lifetime no-cost

health benefits. The trial court found plaintiff was not "hired" when he accepted

the offer of employment prior to July 1, but instead was "hired" after that date,

when he took the oath of office and commenced his employment. Having

viewed the record under the controlling resolution, we affirm. We also discern

no error in the trial court's decision withholding privileged communications

between Fitzgerald as county counsel and O'Connor as county administrator

concerning the benefits determination.

I.

We derive the following facts from the summary judgment record, viewed

in the light most favorable to plaintiff as the non-moving party. See Friedman

v. Martinez, 242 N.J. 450, 472 (2020). Very little is disputed about what

occurred and when.

2 The then-Monmouth County Board of Chosen Freeholders (the Board) is now known as the Monmouth County Board of County Commissioners. For accuracy, we cite to the Board's resolution in accordance with its prior designation. A-3602-24 3 Plaintiff retired in February 2022 from the Monmouth County

Prosecutor's Office (MCPO) after more than twenty-seven years of service.

Formerly a Staten Island assistant district attorney, plaintiff applied to the

MCPO in April 1994. After an interview with the county prosecutor in May

1994, he was offered the position.

In a letter dated June 1, 1994 to the former county administrator, the then-

MCPO second-assistant prosecutor advised: "[Plaintiff] has accepted the

position of assistant prosecutor with the [MCPO and] . . . will be starting in his

new position on July 18, 1994." In a memo dated June 2, the county

administrator responded to the second assistant, stating: "Authorization is given

to hire [plaintiff] effective July 18, 1994." A handwritten note on the copy of

the memo provided in plaintiff's appendix states, "6/15 paper wk on its way"

and, in parentheses, "new hire letter."

It is undisputed plaintiff was required to complete substantial paperwork,

and plaintiff provided an undated checklist of nineteen specific forms, with

handwritten checkmarks next to each. A form entitled, "Personnel Action

Request Form," dated June 27, 1994, from the MCPO to the "Personnel

Department," requested plaintiff be approved to "fill" a particular vacancy as an

assistant prosecutor with a requested "effective date" of "July 18, 1994." The

A-3602-24 4 request further projected the "length of time needed" to be "from 7/18/94 to

indefinite," at a set salary. The form was stamped "APPROVED" at the bottom,

with a handwritten date of "7/1/94" and initials next to the signature of Thomas

A. Mion, the MCPO office manager at the time.

Importantly, however, plaintiff's employment was conditioned upon his

satisfactorily clearing a mandatory background check and taking the oath of

office. Plaintiff took the oath of office on July 18, 1994—his first day of work

at MCPO and the date he first became "pension eligible."

Unbeknownst to plaintiff at the time he applied for, accepted, and

commenced employment with the MCPO, the County revised its health benefits

policy for county employees, eliminating lifetime no-cost health benefits upon

retirement for those employees "hired" after July 1, 1994. Specifically, on April

14, 1994, the Board adopted Resolution 94-267 which provided in relevant part:

BE IT FURTHER RESOLVED that any new employee hired after July 1, 1994 will not, regardless of their years of service anywhere, be allowed to retire from Monmouth County with any health benefits at no cost.

BE IT FURTHER RESOLVED that any employee hired by the County on or after July 1, 1994 will not be permitted to enroll in the County's Self- Funded Indemnity Plan.

A-3602-24 5 BE IT FURTHER RESOLVED that all active employees hired on or before June 30, 1994 will be able to participate in either the County's Self-Funded Indemnity Plan by having the appropriate deduction made from each paycheck or in the County's Self- Funded Point-of-Service Plan at no cost and that all of these active[] employees may, during their active employment only, choose between the Self-Funded Indemnity Plan and the Self-Funded Point-of-Service Plan each year during the Open Enrollment period only.

[Monmouth County, N.J., Bd. of Chosen Freeholders Res. 94-267 (Apr. 14, 1994).] Prior to the resolution, the County provided no-cost lifetime health benefits for

employees retiring after more than twenty-five years of service.

Years later, in December 2021, when contemplating retirement, plaintiff

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