Lois Henry v. Township of Cranford

CourtNew Jersey Superior Court Appellate Division
DecidedNovember 15, 2024
DocketA-0844-23
StatusUnpublished

This text of Lois Henry v. Township of Cranford (Lois Henry v. Township of Cranford) 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
Lois Henry v. Township of Cranford, (N.J. Ct. App. 2024).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-0844-23

LOIS HENRY,

Plaintiff-Appellant,

v.

TOWNSHIP OF CRANFORD and CRANFORD CONSERVATION CENTER,

Defendants-Respondents. ______________________________

Submitted October 28, 2024 – Decided November 15, 2024

Before Judges Sabatino and Berdote Byrne.

On appeal from the Superior Court of New Jersey, Law Division, Union County, Docket No. L-0640-22.

Lord, Kobrin, Alvarez & Fattell, LLC, attorneys for appellant (Craig J. Kobrin and Paula C. Nunes, on the briefs).

Savo, Schalk, Corsini, Warner, Gillespie, O'Grodnick & Fisher, PA, attorneys for respondents (Matthew R. Flynn, of counsel and on the brief).

PER CURIAM In this slip-and-fall case, plaintiff Lois Henry appeals the trial court's

order granting summary judgment and dismissing her complaint under the Tort

Claims Act, N.J.S.A. 59:1-1 to 12-3 ("TCA") against defendants Township of

Cranford and the Cranford Conservation Center, and the court's subsequent

denial of reconsideration. We affirm.

The underlying facts may be simply stated. On April 7, 2021, plaintiff

arrived at the Cranford Conservation Center, a recycling facility owned and

maintained by the Township. The Center provides a place for residents to

dispose of their recycling and yard waste. It is staffed by part-time members of

the Township's Department of Public Works ("DPW").

When visitors arrive at the site, they pass a small entrance building where

employees are located, and then a paved driveway leads them to various box

cars designated for different types of recycling. In front of the containers is a

filler of mixed stones of varying shapes and sizes to prevent puddling and icy

conditions from forming in front of the recycling containers that are not

connected to the paved road.

Plaintiff tripped and fell returning to her car after dropping off recycling

in one such box car. She described the incident as follows: "[O]n the way out

I put my foot down and there are a lot of rocks and gravel there, and when I put

A-0844-23 2 my foot down . . . it twisted on—I stepped on a rock and my foot twisted . . .

and I went right down on my knee."

Although other members of the public and a DPW employee were present

when she fell, plaintiff did not interact with anyone and drove home on her own.

Her spouse drove her to an urgent care facility, which diagnosed plaintiff with

a fracture of her fifth metatarsal on her right foot. Plaintiff's spouse returned to

the Center to take photographs of a box car like the one at which she tripped.

Plaintiff sued defendants under the TCA, contending the gravel and filler

at the site comprised a dangerous condition of public property. The Director of

the Township's DPW, Erik Hastrup, testified in his deposition that the filler was

placed in front of the box car to avoid puddling and icy conditions. Hastrup

stated he inspected the area whenever he visited, and that employees were there

to keep things in order but that there were no scheduled inspections or specific

regulations regarding the filler. He was unaware of any previous incidents at

the location.

An employee on site at the time of the accident, Jeremy Slivinski, testified

that he did not remember the incident and did not observe it. He further testified

that he never received any complaints about the stone filler, and there had been

A-0844-23 3 no other accidents he knew of, but that he was aware of some people losing their

balance on the stones.

After discovery ended, defendants moved for summary judgment. On

October 6, 2023, Judge John Hudak granted the motion and dismissed the

complaint with prejudice after rendering an oral opinion. Plaintiff moved for

reconsideration, which was denied in an order dated November 17, 2023.

On appeal, plaintiff argues the court erred in granting summary judgment.

She contends there are genuine issues of material fact concerning various

elements of dangerous condition liability under the TCA.

In considering plaintiff's appeal we adhere to well-established principles

governing summary judgment practice and liability under the TCA. On a

summary judgment motion, a court must view the motion record in a light most

favorable to the non-moving party, here plaintiff. Brill v. Guardian Life Ins.

Co. of Am., 142 N.J. 520, 528–29 (1995); see also R. 4:46-1 to -6. On appeal

we apply the same perspective. Statewide Ins. Fund v. Star Ins. Co., 253 N.J.

119, 124–25 (2023). We review a grant of summary judgment de novo. Ibid.

As to the TCA, we are mindful "[t]he Legislature passed the TCA after

this Court abolished the common law doctrine of sovereign immunity . . . ."

Stewart v. N.J. Tpk. Auth., 249 N.J. 642, 655 (2022) (citing Vincitore ex rel.

A-0844-23 4 Vincitore v. N.J. Sports & Exposition Auth., 169 N.J. 119, 124 (2001)). "In

doing so, the Legislature provided that public entities could be held liable for

negligence 'within the limitations of [the TCA].'" Ibid. (alteration in original)

(quoting N.J.S.A. 59:1-2). "[T]he 'guiding principle' of the [TCA] is 'that

"immunity from tort liability is the general rule and liability is the exception."'"

D.D. v. Univ. of Med. & Dentistry of N.J., 213 N.J. 130, 134 (2013).

Under the terms of the TCA, a public entity may be liable for a personal

injury caused by the "dangerous condition" of its public property. N.J.S.A. 59:4-

2. "The applicable standards for dangerous condition liability under the TCA

are well established. To recover for an injury under the general liability section

of the TCA, N.J.S.A. 59:4-2, a plaintiff must prove several elements." Estate of

Massi v. Barr, 479 N.J. Super. 144, 156 (App. Div. 2024). The statute

prescribes:

A public entity is liable for injury caused by a condition of its property if the plaintiff establishes that [(1)] the property was in dangerous condition at the time of the injury, [(2)] that the injury was proximately caused by the dangerous condition, [(3)] that the dangerous condition created a reasonably foreseeable risk of the kind of injury which was incurred, and [(4)] that either:

a. a negligent or wrongful act or omission of an employee of the public entity within the scope of his employment created the dangerous condition; or

A-0844-23 5 b. a public entity had actual or constructive notice of the dangerous condition under [N.J.S.A.] 59:4-3 a sufficient time prior to the injury to have taken measures to protect against the dangerous condition.

Nothing in this section shall be construed to impose liability upon a public entity for a dangerous condition of its public property if the action the entity took to protect against the condition or the failure to take such action was not palpably unreasonable.

[N.J.S.A. 59:4-2 (emphases added).]

The TCA defines a dangerous condition of property as a condition that

"creates a substantial risk of injury when such property is used with due care in

a manner in which it is reasonably foreseeable that it will be used." N.J.S.A.

59:4-1(a).

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

Related

Coyne v. State, Department of Transportation
867 A.2d 1159 (Supreme Court of New Jersey, 2005)
Chatman v. Hall
608 A.2d 263 (Supreme Court of New Jersey, 1992)
Garrison v. Township of Middletown
712 A.2d 1101 (Supreme Court of New Jersey, 1998)
Kolitch v. Lindedahl
497 A.2d 183 (Supreme Court of New Jersey, 1985)
Polyard v. Terry
390 A.2d 653 (New Jersey Superior Court App Division, 1978)
Brill v. Guardian Life Insurance Co. of America
666 A.2d 146 (Supreme Court of New Jersey, 1995)
Vincitore v. New Jersey Sports & Exposition Authority
777 A.2d 9 (Supreme Court of New Jersey, 2001)
D.D. v. University of Medicine & Dentistry
61 A.3d 906 (Supreme Court of New Jersey, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Lois Henry v. Township of Cranford, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lois-henry-v-township-of-cranford-njsuperctappdiv-2024.