Marielle Kuczinski v. State of New Jersey

New Jersey Superior Court Appellate Division·Decided September 4, 2026·No. A-3232-23·Unpublished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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-3232-23

MARIELLE KUCZINSKI, Plaintiff-Appellant,

v.

STATE OF NEW JERSEY and NEW JERSEY STATE POLICE,

Defendants-Respondents,

and

MARQUICE D. PRATHER, individually, and in his official capacity,

Defendant.

Argued February 3, 2026 – Decided September 4, 2026 Before Judges Gooden Brown and Rose.

On appeal from the Superior Court of New Jersey, Law Division, Middlesex County, Docket No. L-0225-18.

Fredrick L. Rubenstein argued the cause for appellant (Shah & Rubenstein, LLC, attorneys; Fredrick L.

Rubenstein, on the briefs).

Dorothy M. Rodriguez argued the cause for respondent (Jennifer Davenport, Acting Attorney General, attorney; Sookie Bae-Park, Assistant Attorney General, of counsel; Azeem M. Chaudry and Andrew D.

Spevack, Deputy Attorneys General, on the brief).

PER CURIAM Plaintiff Marielle Kuczinski appeals from the summary judgment dismissal of her complaint against defendants the State of New Jersey and the New Jersey State Police (collectively, State defendants). Defendant Marquice D. Prather, a former State Trooper who was terminated for his reprehensible conduct during motor vehicle stops, defaulted and is not a party to this appeal.

Plaintiff filed suit after learning Prather had been investigated for allegedly seizing women's cell phones during traffic stops, searching the phones for explicit photos and then disseminating some of the photos. Plaintiff had been stopped by Prather and her cell phone seized under similar circumstances as confirmed victims. In a May 9, 2024 order, the motion judge granted summary judgment to the State defendants, dismissing plaintiff's complaint as to all counts with prejudice. We affirm substantially for the reasons outlined in the judge's comprehensive and thorough written opinion.

A-3232-23

I.

We summarize the pertinent facts and events from the motion record in a light most favorable to plaintiff as the non-moving party. See R. 4:46-2(c); Brill v. Guardian Life Ins. Co. of Am., 142 N.J. 520, 540 (1995).

At approximately 10:10 p.m. on January 13, 2016, Prather pulled over plaintiff on Interstate 95 in Hamilton Township. On a "Digital-In-Vehicle Recording" (DIVR) documenting the stop, Prather could be heard telling plaintiff he pulled her over because she went over the line on Interstate 95 and had a hard time maintaining her lane.

Plaintiff had an expired insurance card when she was stopped. Although there are gaps in the DIVR, plaintiff asked if she could contact someone in her family to send her a picture of the updated insurance, and Prather agreed. When plaintiff received the photo, she handed her cell phone with the texted picture to Prather, who took it to his vehicle. Prather had plaintiff's cell phone for approximately ten to twelve minutes, at which point he returned to plaintiff's car, returned the cell phone, and issued her a written warning. Plaintiff stated at her deposition "the vehicle stop itself did not raise any red flags that anything wrong had occurred" and Prather said nothing inappropriate or provocative.

The State Police Office of Professional Standards (OPS) commenced an

A-3232-23

internal investigation into Prather after three complaints were made against him by female motorists. Two motorists alleged he took their cell phones during traffic stops and the third motorist alleged he requested sexual favors from her in exchange for leniency during the stop. The investigation involved "installing surveillance equipment in Prather's vehicle, interviewing Prather, extracting information from the complainants' cell[ ]phones, extracting information and text messages from Prather's cell[ ]phone, obtaining records from Prather's cell[ ]phone provider, interviewing complainants, and examining . . . DIVR footage."

As recounted by the judge, an Affidavit of Probable Cause signed by OPS Lieutenant Joseph Tietjen on December 9, 2016, detailed the investigation's results:

Prather would take custody of women motorists'

cell[ ]phones for a period of time during the stops and reviewed them in his car. During his employment as a State Trooper, Prather would use his position to request women's cell[ ]phone numbers and/or provide his number to them during motor vehicle stops and would subsequently contact them or ask them to contact him.

The State [d]efendants contend that there is no evidence to suggest that Prather engaged in this behavior toward [plaintiff].

The Affidavit of Probable Cause further stated that inquiries of vehicles that were registered to females between the ages of [twenty to thirty-five] were often followed up with driver's license number inquiries that would provide [Motor Vehicle Commission]

A-3232-23

photographs of those women to Prather. . . .[1] Prather had also falsely reported drivers' genders as male to disguise the fact that he stopped a high number of females. . . . [T]here were . . . two occasions where it was revealed that Prather intentionally deactivated his wireless microphone, during the period from November 25-27, 2016.

Prather was arrested on December 9, 2016. Approximately one month later, in January 2017, Tietjen and another unidentified officer came to plaintiff's residence to inform her that Prather was being investigated. At her deposition, plaintiff testified the officers told her she was "definitely a victim of a crime." Plaintiff had "sexually explicit photos on her cell[ ]phone at the time of her motor vehicle stop" and was told Prather "had her cell[ ]phone photos." Plaintiff consented to an analysis of her cell phone to determine whether "any of those photos had been disseminated."

According to plaintiff, the officers told her that her "stop time" was "way over the normal limit," and that she fit the "mold" of women Prather had victimized. They also asked her if Prather had been inappropriate, had asked for her phone number, or had "stalked" her, none of which had occurred. In his deposition, Tietjen agreed Prather's actions constituted an unlawful seizure.

1 The State denies such actions occurred involving plaintiff.

A-3232-23

However, Tietjen asserted his practice was to inform potential victims "there was the suspicion that [Prather] may have accessed something on their [cell] phones," rather than to tell them they were "a victim of a crime."

Plaintiff's brother, who was present when Tietjen visited plaintiff, testified in his deposition that one of the troopers told plaintiff she may have been the victim of a crime. However, plaintiff's father, who was also present, testified in his deposition that one of the troopers told plaintiff she was a victim of a crime.

After the visit to plaintiff's residence, plaintiff was interviewed by OPS on January 17, 2017. During the interview, plaintiff stated she had been driving home from a friend's house when she was pulled over by Prather. She had noticed the police car following her "for some time." After she was pulled over and while she was waiting for her parents to send over a picture of her insurance, the two made "small talk" but plaintiff did not recall Prather discussing her "unsafe lane change."

According to plaintiff, Prather stated he needed to "flash [the picture of the insurance card] to a camera" in his car. Upon receiving the picture, plaintiff gave Prather her cell phone and he went back to his car. Plaintiff noted "[h]e was in the car for what seemed like a little bit longer than usual," but she thought it may have been "protocol." She recalled seeing a "shadow of a light going

A-3232-23

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

Marielle Kuczinski v. State of New Jersey, (N.J. Ct. App. 2026).

Marielle Kuczinski v. State of New Jersey (Marielle Kuczinski v. State of New Jersey) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Borough of Saddle River v. 66 East Allendale, LLC (070525)
77 A.3d 1161 (Supreme Court of New Jersey, 2013)
Massachi v. AHL Services, Inc.
935 A.2d 769 (New Jersey Superior Court App Division, 2007)
Turner v. Wong
832 A.2d 340 (New Jersey Superior Court App Division, 2003)
Russo v. Nagel
817 A.2d 426 (New Jersey Superior Court App Division, 2003)
State v. Odom
560 A.2d 1198 (Supreme Court of New Jersey, 1989)
Vuocolo v. Diamond Shamrock Chem.
573 A.2d 196 (New Jersey Superior Court App Division, 1990)
Ptaszynski v. Uwaneme
853 A.2d 288 (New Jersey Superior Court App Division, 2004)
Flagg v. Essex County Prosecutor
796 A.2d 182 (Supreme Court of New Jersey, 2002)
L.W. v. Toms River Regional Schools Board of Education
915 A.2d 535 (Supreme Court of New Jersey, 2007)
Bergen Commercial Bank v. Sisler
723 A.2d 944 (Supreme Court of New Jersey, 1999)
Rumbauskas v. Cantor
649 A.2d 853 (Supreme Court of New Jersey, 1994)
Di Cosala v. Kay
450 A.2d 508 (Supreme Court of New Jersey, 1982)
Pomerantz Paper Corp. v. New Community Corp.
25 A.3d 221 (Supreme Court of New Jersey, 2011)
Marley v. Palmyra Bor.
473 A.2d 554 (New Jersey Superior Court App Division, 1983)
Brill v. Guardian Life Insurance Co. of America
666 A.2d 146 (Supreme Court of New Jersey, 1995)
G.D. v. Kenny
15 A.3d 300 (Supreme Court of New Jersey, 2011)
Amratlal C. Bhagat v. Bharat A. Bhagat (068312)
84 A.3d 583 (Supreme Court of New Jersey, 2014)
Deborah Townsend v. Noah Pierre (072357)
110 A.3d 52 (Supreme Court of New Jersey, 2015)
Denise Brown v. State of New Jersey and John Steet
124 A.3d 243 (New Jersey Superior Court App Division, 2015)