Marcellus Allen v. City of Newark

CourtNew Jersey Superior Court Appellate Division
DecidedApril 11, 2025
DocketA-2366-23
StatusUnpublished

This text of Marcellus Allen v. City of Newark (Marcellus Allen v. City of Newark) 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
Marcellus Allen v. City of Newark, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2366-23

MARCELLUS ALLEN,

Plaintiff-Appellant,

v.

CITY OF NEWARK, and JOSEPH A. MCCALLUM, JR., individually and in his official capacity,

Defendants-Respondents. ___________________________

Argued March 24, 2025 – Decided April 11, 2025

Before Judges Sabatino, Berdote Byrne and Jacobs.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. L-0273-20.

Tracey S. Cosby (Tracey S. Cosby, PC) argued the cause for appellant.

Marc D. Haefner argued the cause for respondents (Walsh Pizzi O'Reilly Falanga LLP, attorneys; Marc D. Haefner, Gerhard W. Buehning, and Fabian N. Marriott, on the brief). PER CURIAM

Plaintiff Marcellus Allen appeals the trial court's decision granting

defendants' motion for summary judgment. Plaintiff was formerly employed as

an Aide Level I for defendant Councilman Joseph A. McCallum, Jr. in the West

Ward of the City of Newark until he was terminated on January 12, 2018.

Plaintiff sued defendants in a four-count complaint alleging his termination was

wrongful, amounted to a breach of contract, and violated his right to free speech.

Plaintiff also alleged McCallum improperly cast him in a false light by calling

him a "thug" after his termination, allegedly referring to plaintiff's past criminal

history.

Prior to his termination, plaintiff had sought petitions from West Ward

constituents in a bid to challenge McCallum in an upcoming election. Plaintiff

argues this entitled him to the protections afforded by Newark Executive Order

MEO-08-0001 ("Executive Order"), which provides any individual "certified as

a candidate for municipal elective office in the City of Newark or for county

elective office in the County of Essex shall be entitled to maintain their position

with the City of Newark."

Additionally, plaintiff contends he was a union-represented employee

protected by a collective bargaining agreement ("CBA") and claims his

A-2366-23 2 employment was terminable only "for cause" based on the CBA and his

employee handbook. And he claims his termination violated his constitutional

first amendment right to speak freely. The trial judge granted defendants'

motion for summary judgment dismissing all four counts.

We conclude the Executive Order did not apply to plaintiff as he was not

a "certified" candidate prior to being terminated. However, we reverse the trial

court's dismissal of counts one and two, which allege wrongful termination and

breach of contract respectively, because a genuine issue of material fact exists

as to whether plaintiff was an employee terminable at will, or an employee

subject to the CBA and terminable only for cause. Also, plaintiff alleges his

free speech rights were violated in a stand-alone count -- count three – and he is

entitled to monetary relief from the City of Newark, although his allegations are

tied to his wrongful termination count. The trial court failed to make any

findings of fact or conclusions of law with respect to count three, constraining

us to reinstate count three for an evaluation of whether plaintiff's free speech

rights were violated by his termination.

Finally, plaintiff's false light claim was properly dismissed as it was time-

barred by the relevant statute of limitations, and his alternative argument,

applying a two-year statute of limitations is unavailing.

A-2366-23 3 I.

Plaintiff was employed as an Aide Level I for McCallum in the West Ward

of Newark until his termination on January 12, 2018. Plaintiff's termination

notice, in its entirety, reads as follows:

Dear Mr. Allen:

Please be advised as of January 12, 2018 your services, as an Aide to the Councilman will no longer be needed and will terminate at the close of business today. Thank you for your services to the City and I wish you well in your future endeavors.

Sincerely,

Joseph A. McCallum West Ward Councilman

Days before plaintiff was terminated, McCallum was informed plaintiff

was seeking petitions for candidacy to run against him in an upcoming election.

On January 30, 2018, over two weeks after his termination, plaintiff was notified

he had insufficient petitions to have his candidacy certified. This notice

informed plaintiff he had 206 accepted petitions but needed at least 307 accepted

petitions to become certified. It was not until February 22, 2018, over a month

after his termination, that plaintiff was notified he had met the threshold of 307

accepted petitions, and he was certified at that point to run for office in the City

of Newark. Plaintiff filed a four-count complaint and demand for jury trial,

A-2366-23 4 alleging: (1) wrongful termination ("count one");1 (2) breach of contract and

breach of the implied covenant of good faith and fair dealing ("count two"); (3)

violation of Article I, Paragraphs 1 and 6 of the New Jersey Constitution,

regarding freedom of speech ("count three"); and (4) casting plaintiff in a false

light ("count four").

During discovery, plaintiff deposed the Assistant Business Administrator

for the City of Newark, who also was the former Personnel Director for the City

of Newark. She testified plaintiff's position was union-represented, and

plaintiff's union was not notified of or involved in plaintiff's termination.

Plaintiff also deposed McCallum, who testified he thought it was "ridiculous"

plaintiff was running against him while still in his employ, and contended he

terminated plaintiff for general insubordination and taking unauthorized

vacations. McCallum also conceded a union was not involved when terminating

plaintiff.

1 Count one also alleges a violation of the New Jersey Law Against Discrimination ("NJLAD"), N.J.S.A. 10:5-1 to -50. This portion of count one was dismissed on August 19, 2020. The order specifies "[a]ll claims and crossclaims other than the NJLAD claim are not dismissed." Accordingly, defendants' contention in their brief that only counts two, three, and four remain on appeal is incorrect. Moreover, at oral argument for summary judgment, defendants stated count one remained despite the August 19, 2020 order regarding the NJLAD allegation. A-2366-23 5 At the close of discovery, defendants moved for summary judgment. In

the brief oral decision rendered, the trial court dismissed all counts, ruling the

Executive Order did not apply to plaintiff, plaintiff improperly failed to exhaust

the CBA's grievance procedures before seeking judicial relief, and plaintiff's

false light claim was time-barred by a one-year statute of limitations. The trial

court did not make any determinations as to the employee handbook's provisions

nor did it make any findings of fact or conclusions of law with respect to

plaintiff's free speech claim. This appeal followed.

II.

In considering these arguments, we review the trial court's grant of

summary judgment de novo. Branch v. Cream-O-Land Dairy, 244 N.J. 567, 582

(2021). We consider the factual record, and reasonable inferences that can be

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