Lawrence Digiesi v. Township of Bridgewater Police Department

CourtNew Jersey Superior Court Appellate Division
DecidedJuly 23, 2025
DocketA-0107-24
StatusUnpublished

This text of Lawrence Digiesi v. Township of Bridgewater Police Department (Lawrence Digiesi v. Township of Bridgewater Police Department) 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.

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Lawrence Digiesi v. Township of Bridgewater Police Department, (N.J. Ct. App. 2025).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-0107-24

LAWRENCE DIGIESI,

Plaintiff-Appellant,

v.

TOWNSHIP OF BRIDGEWATER POLICE DEPARTMENT, TOWNSHIP OF BRIDGEWATER, THOMAS KOCHANSKI, PETER OCHS, JOHN MITZAK, and SHAWN O'NEILL,

Defendants-Respondents,

and

ALFRED NICARETTA, KENNETH DOLIDA, and PAUL PAYNE,

Defendants. _________________________________

Argued June 4, 2025 – Decided July 23, 2025

Before Judges Mayer, Rose and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Somerset County, Docket No. L-0453-24. Peter W. Till argued the cause for appellant (Law Offices of Peter W. Till, attorneys; Peter W. Till and John V. Salierno, on the briefs).

Matthew R. Flynn argued the cause for respondents Township of Bridgewater and Township of Bridgewater Police Department (Savo, Schalk, Corsini, Warner, Gillespie, O'Grodnick & Fisher, PA, attorneys; Matthew R. Flynn, of counsel and on the brief).

Richard J. Guss argued the cause for respondents Thomas Kochanski, Peter Ochs, John Mitzak, and Shawn O'Neill (DiFrancesco, Bateman, Kunzman, Davis, Lehrer & Flaum, PC, attorneys; Richard J. Guss, on the brief).

PER CURIAM

Plaintiff Lawrence DiGiesi appeals from the August 16, 2024 Law

Division orders dismissing his complaint against defendants Township of

Bridgewater Police Department and Township of Bridgewater (Bridgewater

defendants), and Thomas Kochanski, Peter Ochs, John Mitzak, and Shawn

O'Neill (individual defendants). We reverse.

I.

Plaintiff was employed as a restaurant security guard in Bridgewater. On

March 13, 2016, plaintiff refused re-entry to two patrons because they were

belligerent to restaurant staff. One of the patrons, who was the son of a retired

Bridgewater police officer, became enraged at being barred from reentry and

A-0107-24 2 engaged in a physical altercation with plaintiff. When plaintiff pushed the

patron away from him, the patron fell and sustained an ankle injury.

The police were called, and Mitzak, O'Neill and Kochanski responded to

investigate the incident but did not arrest anyone that night. Six days later,

Mitzak prepared an incident report stating he reviewed surveillance footage of

the incident and "it [was] obvious that [plaintiff was] the aggressor"; "[a]t no

time did [he] see [the patron] attempt to re-enter the [restaurant]"; "and at no

time did [he] see [the patron] push or punch [plaintiff]."

On September 22, 2016, a Somerset County grand jury indicted plaintiff,

charging him with third-degree aggravated assault, N.J.S.A. 2C:12-1(b)(7). On

June 6, 2017, plaintiff was found not guilty in a bench trial, but the judgment of

acquittal (JOA) was not entered until July 31, 2017.

On July 1, 2019, plaintiff filed a nine-count complaint in the District of

New Jersey (federal complaint) pursuant to 42 U.S.C. § 1983 and the New Jersey

Tort Claims Act (TCA), N.J.S.A. 59:1-1 to -7, alleging: violations of the

Fourteenth Amendment to the United States Constitution (count one);

negligence (count two); malicious abuse of legal process (count three);

malicious prosecution (count four); violations of his constitutional rights by

falsely, wrongfully, detaining and arresting him (count five); defamatory injury

A-0107-24 3 to reputation (count six); aiding in the commission of tort by concert of action

(count seven); and conspiracy to commit tort (count eight); and municipal

liability (count nine). Counts one through seven were alleged against all

defendants,1 and count nine was alleged against Bridgewater Township.

On March 27, 2024, the district court dismissed the federal claims as time-

barred, because the false arrest claims2 were filed more than two years after

plaintiff's arrest and the malicious prosecution claims were filed more than two

years after the prosecution was terminated in his favor on June 6, 2017. The

court declined to exercise supplemental jurisdiction over the remaining state law

claims and dismissed them without prejudice. Plaintiff appealed the order to the

Third Circuit.

On April 11, 2024, plaintiff filed a ten-count complaint in state court (state

complaint) pursuant to the New Jersey Civil Rights Act, N.J.S.A. 10:6-1 to -2

(NJCRA) and the TCA, alleging: unlawful detention, in violation of (count

one); false imprisonment, in violation of N.J.S.A. 2C:30-6 (count two);

1 The federal complaint also named other individuals who were not named as defendants in this matter. 2 For brevity and because of the distinct accrual dates, we refer to plaintiff's various claims arising out of his arrest and imprisonment as false arrest claims and the claims arising out of his prosecution as malicious prosecution claims. A-0107-24 4 violations of the New Jersey Constitution (count three); negligence, in violation

of the TCA (count four); malicious abuse of legal process (count five); malicious

prosecution and use of process (count six); malicious misrepresentation (count

seven); aiding the commission of tort—concert of action (count eight); civil

conspiracy (count nine); and municipal liability (count ten). 3

The individual and Bridgewater defendants moved to dismiss the state

complaint pursuant to Rule 4:6-2(e) for failure to file within the two-year statute

of limitations. 4 In its August 16, 2024 oral decision, the trial court noted it was

not bound by the district court's ruling, but nevertheless "agree[d] with [the]

calculation of the commencement of the accrual date," because the district court

"was dealing with the same statute of limitations."

Likening the issue to the discovery rule, the trial court opined "[t]he

accrual date . . . is triggered on the date of the discovery of the injury by the

plaintiff or from the date when through the exercise of reasonable diligence such

injury should have been discovered by the plaintiff, whichever is later." Thus,

3 Except for count ten, which was alleged against Bridgewater Township, the causes of action were alleged against all defendants. Because of the different accrual dates, we refer to plaintiff's allegations as either related to his arrest or related to his prosecution. 4 The parties do not dispute the entirety of plaintiff's claims are subject to a two- year statute of limitations. A-0107-24 5 the court found plaintiff's malicious prosecution claims accrued "at the time

[plaintiff] was in court and he was found not guilty." Accordingly, the court

granted defendants' motions and dismissed the state complaint with prejudice as

time barred.

While this appeal was pending, the Third Circuit reversed in part the

March 27, 2024 district court order, holding plaintiff's malicious prosecution

claims accrued when the JOA was entered on July 31, 2017, and were therefore

filed within the two-year statute of limitations period.5 DiGiesi v. Twp. of

Bridgewater Police Dep't, No. 24-1768, 2025 U.S. App. LEXIS 10080, at *4-5

(3d Cir. Apr. 28, 2025). The Third Circuit reasoned:

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