John M. Gately and Patty Sue Gately v. Hamilton

125 A.3d 747, 442 N.J. Super. 542
CourtNew Jersey Superior Court Appellate Division
DecidedOctober 22, 2015
DocketA-4458-13T2
StatusPublished
Cited by2 cases

This text of 125 A.3d 747 (John M. Gately and Patty Sue Gately v. Hamilton) 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
John M. Gately and Patty Sue Gately v. Hamilton, 125 A.3d 747, 442 N.J. Super. 542 (N.J. Ct. App. 2015).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4458-13T2

JOHN M. GATELY and PATTY SUE GATELY (h/w), APPROVED FOR PUBLICATION Plaintiffs-Appellants, October 22, 2015 v. APPELLATE DIVISION

HAMILTON MEMORIAL HOME, INC., d/b/a BRENNA-CELLINI FUNERAL HOME, and MARIA E. BRENNA,

Defendants-Respondents. __________________________________

Argued September 21, 2015 - Decided October 22, 2015

Before Judges Sabatino, Accurso, and O'Connor.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County, Docket No. L-2047-11.

Gary F. Piserchia argued the cause for appellants (Parker McCay, P.A., attorneys; Stacy L. Moore, Jr., of counsel; Mr. Piserchia, on the brief).

Lionel J. Frank argued the cause for respondent Hamilton Memorial Home, Inc., and for respondent Maria E. Brenna only as to Counts One and Three of the Amended Complaint (Szaferman, Lakind, Blumstein & Blader, P.C., attorneys; Mr. Frank, Jeffrey P. Blumstein, and Melissa A. Chimbangu, on the brief).

William E. Paulus argued the cause for respondent Maria A. Brenna as to Counts Two and Four of the Amended Complaint (Law Office of Gerard M. Green, attorneys; Mr. Paulus, on the brief).

The opinion of the court was delivered by,

SABATINO, P.J.A.D.

This appeal arises out of a no-cause jury verdict rejecting

a father's claims that a funeral home wrongfully released the

remains of his adult son for cremation without the father's

authorization. The father contends that he told an individual

employed by the home (known in the trade as an "intern") that he

did not want his son to be cremated. He claims that the intern

and funeral home ignored his protestations and instead

improperly acceded to the contrary direction of the decedent's

mother. The father and his current wife, as co-plaintiffs,

argue that the trial court erred by instructing the jury that

defendants' conduct is subject to protection under qualified

statutory immunities, and that the verdict was unjust and

against the weight of the evidence.

The main and novel legal issue presented to us is whether

the qualified immunity from civil liability granted to funeral

directors under N.J.S.A. 45:7-95 and N.J.S.A. 45:27-22(d)

extends to interns who are employed by funeral homes pursuant to

regulations issued by the State Board of Mortuary Science. The

immunity precludes liability unless the defendant had

2 A-4458-13T2 "reasonable notice" of untrue representations or a lack of

authorization by the surviving next of kin.

We conclude that the statutory immunity does extend to such

interns, and that the trial judge consequently did not err in

charging the elements of the immunity to the jury. We further

conclude that the verdict was not against the weight of the

evidence, and that there are no other grounds for ordering a new

trial.

I.

On October 16, 2009, John R. Gately, son of Kathleen

Cousminer and plaintiff John M. Gately, was killed in an

automobile accident.1 Cousminer and Gately divorced in 1988 or

1989 when their son was about five years old. Both parents have

since remarried.

Although Cousminer had custody of the son while he was a

minor, Gately contends he had a close relationship with the

young man. At the time of his death, the son was living with

Cousminer in New Jersey. Plaintiffs were residing in Florida.

1 To avoid confusion, we refer to John M. Gately as "Gately," his current wife Patty Sue Gately as "Patty" and the deceased as the "son." In doing so, we intend no disrespect. Gately and Patty collectively will be referred to as "plaintiffs."

3 A-4458-13T2 Following the son's death, Cousminer's husband called

Brenna-Cellini Funeral Home2 and set up an appointment for

Monday, October 19, 2009 to make the funeral arrangements.

Cousminer and her husband met with defendant Maria E. Brenna,

who was then a licensed intern employed by the home, to make the

arrangements. Cousminer stated that she wanted the son

cremated. She signed a Cremation Authorization and Disposition

Order (the "Authorization Form") supplied to her by Brenna.

Among other things, the Authorization Form certified that the

signer "is of mature age and alone [has] the right [to] give

this authorization and direction for said cremation, and that no

other person has such right[.]"

The home's funeral director, Joe D'Errico,3 was in an

adjoining room while those arrangements were being made.

According to Brenna, D'Errico was not required to be in the room

with the customer but he had to be available to review and sign

the documents. Brenna testified that D'Errico escorted

Cousminer into the funeral home, and that he was present when

she met with them.

2 This is the business name for defendant Hamilton Memorial Home, Inc. The "Brenna" in the funeral home's name is the surname of the individual co-defendant. 3 According to Brenna's testimony, as of the time of trial, she and D'Errico were "partners" in the funeral home.

4 A-4458-13T2 After the arrangements were made, Cousminer had a

conversation with her ex-husband Gately, who told her he did not

want their son to be cremated. According to her testimony,

Cousminer did not tell Brenna that Gately objected to the

cremation.

Gately testified that he spoke to Brenna by telephone on

Monday, October 19, and told Brenna he did not want the son to

be cremated. Gately claimed that Brenna told him he had no

choice in the matter and that she hung up on him. Corroborating

her husband's account, Patty testified that she overheard

Gately's conversation with Brenna and that he told Brenna he did

not want the son cremated.

A viewing was held at the funeral home on Wednesday,

October 21. Gately testified that he confronted Brenna at the

viewing and again told her he did not want the son cremated.

She allegedly responded that he had no say in the matter. Patty

similarly testified that she saw Gately confront Brenna, and

heard him repeat that he did not want the son cremated. In

addition, Gately's cousin testified that he was with Gately when

he confronted Brenna and heard Gately object to the cremation.

5 A-4458-13T2 The funeral was held on Thursday, October 22.4 Contrary to

plaintiff's testimony, Cousminer testified that Gately did not

express an objection to the cremation to her, either at the

viewing or at the funeral. The son was cremated after his

funeral on that same day.

In her own testimony, Brenna insisted that neither

plaintiffs nor Cousminer ever told her that Gately did not want

the son cremated. Brenna acknowledged that she spoke to

plaintiffs by telephone on October 19, but stated the discussion

was limited to obtaining information for the obituary. She

testified that there was no discussion whatsoever about the son

being cremated.

Brenna denied discussing the cremation with Gately at the

viewing. She testified that her only conversation with

plaintiffs at the viewing was to express her condolences.

Moreover, according to Brenna, her only conversation with

plaintiffs on the day of the funeral was to comply with their

request for a lock of the son's hair and to provide a brochure

of mementos.

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Cite This Page — Counsel Stack

Bluebook (online)
125 A.3d 747, 442 N.J. Super. 542, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-m-gately-and-patty-sue-gately-v-hamilton-njsuperctappdiv-2015.