Mirza M. Bulur v. the New Jersey Office of the Attorney General

CourtNew Jersey Superior Court Appellate Division
DecidedDecember 18, 2024
DocketA-0629-23/A-1209-23
StatusPublished

This text of Mirza M. Bulur v. the New Jersey Office of the Attorney General (Mirza M. Bulur v. the New Jersey Office of the Attorney General) 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
Mirza M. Bulur v. the New Jersey Office of the Attorney General, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0629-23 A-1209-23

MIRZA M. BULUR, in his official capacity as the Acting Public Safety Director for the CITY OF PATERSON and Appropriate Authority, CITY OF APPROVED FOR PUBLICATION PATERSON POLICE DEPARTMENT, December 18, 2024 and ENGELBERT RIBEIRO, in his APPELLATE DIVISION official capacity as the Police Chief of the CITY OF PATERSON POLICE DEPARTMENT,

Plaintiffs-Appellants,

v.

THE NEW JERSEY OFFICE OF THE ATTORNEY GENERAL, MATTHEW J. PLATKIN in his official capacity as Attorney General of the STATE OF NEW JERSEY,

Defendants-Respondents. __________________________________

ANDRE SAYEGH, in his official capacity as the Mayor of the CITY OF PATERSON, and ENGELBERT RIBEIRO, in his official capacity as the Police Chief of the CITY OF PATERSON POLICE DEPARTMENT,

v. ISA M. ABBASSI, in his official capacity as Officer-in-Charge of the PATERSON POLICE DEPARTMENT, THE NEW JERSEY OFFICE OF THE ATTORNEY GENERAL, and MATTHEW J. PLATKIN, in his official capacity as the Attorney General of the STATE OF NEW JERSEY,

Defendants-Respondents. ____________________________________

Argued September 24, 2024 – Decided December 18, 2024

Before Judges Smith, Chase and Vanek.

On appeal from the Superior Court of New Jersey, Law Division, Passaic County, Docket Nos. L-2736-23 and L-3290-23.

Christopher J. Gramiccioni argued the cause for appellants Mirza M. Bulur and Engelbert Ribeiro (Kingston Coventry, LLC, attorneys; Christopher J. Gramiccioni, on the joint briefs).

Edward J. Florio argued the cause for appellant André Sayegh (Florio Kenny Raval, LLP, attorneys; Edward J. Florio and Christopher K. Harriott, on the joint briefs).

Michael Zuckerman, Deputy Solicitor General, argued the cause for respondents (Matthew J. Platkin, Attorney General, attorney; Jeremy M. Feigenbaum, Solicitor General, and Michael L. Zuckerman, of counsel and on the briefs; Robert J. McGuire, Liza B. Fleming, Sidney E. Goldstein, Elizabeth H. Micheletti, Stephanie M. Mignogna, and Michael R. Sarno, Deputy Attorneys General, on the briefs).

A-0629-23 2 Vito A. Gagliardi, Jr., argued the cause for amicus curiae New Jersey State Association of Chiefs of Police (Porzio, Bromberg & Newman, PC, attorneys; Vito A. Gagliardi, Jr., of counsel; David L. Disler and Thomas J. Reilly, on the brief).

Frank G. Marshall, Jr., argued the cause for amicus curiae New Jersey State League of Municipalities (Frank G. Marshall, Jr., on the brief).

The opinion of the court was delivered by

SMITH, J.A.D.

Soon after a tragic incident in Paterson concerning an officer-involved

shooting, the Attorney General (AG) directly superseded, or took over, the

entire Paterson Police Department (PPD), without the consent of city officials.

The AG removed the acting police chief and reassigned him to a position at the

Police Training Commission (PTC). In the chief's place, the AG appointed an

Officer-in-Charge (OIC) to manage the day-to-day administration and

operation of the department. Plaintiffs challenged the AG's supersession in

two lawsuits, asserting the AG's actions in taking over the department and

unilaterally removing the duly appointed chief of police were ultra vires.

This administrative appeal presents us with a question of first

impression: Does the AG have the authority to directly supersede all

operations of a municipal police department without the consent of the

municipality?

A-0629-23 3 After a review of the Criminal Justice Act of 1970, N.J.S.A. 52:17B-97

to -117, as well as other relevant statutes and jurisprudence, we conclude the

answer is no. We reverse the AG's supersession of March 27, 2023, and direct

defendants to reassign the police chief to Paterson from the PTC and restore

day-to-day operational control of the PPD to plaintiffs for the reasons which

follow.

I.

On March 27, 2023, the AG, Matthew J. Platkin,1 directed the Office of

the Attorney General (OAG) to assume full operational control of the PPD's

day-to-day operations. The AG justified the takeover of the department by

citing to, among other things, "the loss of faith in the leadership of the

Department, longstanding fiscal challenges, and mounting public safety

concerns in the City of Paterson." The AG gave written notice of the takeover,

described as a supersession, to Paterson Mayor André Sayegh, Paterson Police

Chief Engelbert Ribeiro, and other officials. In the letter, the AG cited the

OAG's legal authority to carry out the supersession. It stated:

The authority for the Attorney General or a County Prosecutor to supersede a police department is derived from the Criminal Justice Act of 1970, N.J.S.A. 52:17B-97 to -117, and N.J.S.A. 2A:158-4 and -5.

1 Matthew J. Platkin became the AG of the State of New Jersey on February 14, 2022, and has been the AG at all relevant times throughout this litigation.

A-0629-23 4 This authority is also consistent with both decades of practice by the Attorney General and County Prosecutors, as well as a substantial body of case law recognizing the Attorney General's role in overseeing law enforcement agencies as the chief law enforcement officer in the State and the County Prosecutor as the chief law enforcement officer in the county. See, e.g., State v. Winne, 12 N.J. 152 (1953); Williams v. Borough of Clayton, 442 N.J. Super. 583 (App. Div. 2015); Constantine v. Twp. of Bass River, 406 N.J. Super. 305, 327 (App. Div. 2009); State v. Ward, 303 N.J. Super. 47, 52-58 (App. Div. 1997); State v. Downie, 229 N.J. Super. 207, 209 n.1 (App. Div. 1988), aff'd, 117 N.J. 450, certif. denied, 498 U.S. 819 (1990); Kershenblatt v. Kozmor, 264 N.J. Super. 432, 435-38 (Law Div. 1993). (citations reformatted).

That same day, the AG made personnel changes within the police

department, including replacing Chief Ribeiro with an interim Officer -in-

Charge (OIC), New Jersey State Police Major Frederick Fife.

On May 2, 2023, the OAG reassigned Chief Ribeiro to the PTC, which is

located at the Division of Criminal Justice (DCJ) in Trenton. Paterson

opposed Ribeiro's reassignment and proposed that the OAG assign the chief to

City Hall for the duration of the supersession. The OAG rejected the proposal.

Instead, the OAG reduced the transfer to writing, using a memorandum of

understanding (MOU) jointly signed with the police department. Major Fife

signed the MOU on behalf of Paterson and its police department. The AG

A-0629-23 5 replaced Major Fife with Isa M. Abbassi as Officer-In-Charge of the PPD on

May 9, 2023.

While serving in his PTC assignment, Chief Ribeiro was subject to

supervision by the DCJ but remained a paid employee of Paterson.

On the day Chief Ribeiro's PTC assignment was to expire, November 15,

2023, Mayor Sayegh instructed him to report to City Hall the next day. At the

same time, the OAG extended Chief Ribeiro's PTC assignment by six months.

Via email, OIC Abbassi directed Ribeiro to report to the PTC over the Mayor's

objections, and Ribeiro complied. Fife, on behalf of the PPD, and the OAG,

have continued to renew the MOU and it remains in place.

The October 6 Complaint

On October 6, 2023, Public Safety Director Mirza Bulur and Chief

Ribeiro filed a verified complaint in the Law Division pursuant to the Uniform

Declaratory Judgments Act (UDJA), N.J.S.A. 2A:16-50 to -62. They named as

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

Related

National Labor Relations Board v. Wyman-Gordon Co.
394 U.S. 759 (Supreme Court, 1969)
Bennett v. Spear
520 U.S. 154 (Supreme Court, 1997)
Bergen Pines County Hospital v. New Jersey Department of Human Services
476 A.2d 784 (Supreme Court of New Jersey, 1984)
Yurick v. State
875 A.2d 898 (Supreme Court of New Jersey, 2005)
State v. Winne
96 A.2d 63 (Supreme Court of New Jersey, 1953)
State v. Ward
696 A.2d 48 (New Jersey Superior Court App Division, 1997)
Bosland v. Warnock Dodge, Inc.
964 A.2d 741 (Supreme Court of New Jersey, 2009)
In Re Cafra Permit No. 87-0959-5
704 A.2d 1261 (Supreme Court of New Jersey, 1997)
State v. Downie
550 A.2d 1313 (New Jersey Superior Court App Division, 1988)
HOSPICE & PALLIATIVE CARE v. Guhl
997 A.2d 298 (New Jersey Superior Court App Division, 2010)
Frugis v. Bracigliano
827 A.2d 1040 (Supreme Court of New Jersey, 2003)
Cherrits v. Village of Ridgewood
710 A.2d 586 (New Jersey Superior Court App Division, 1998)
Constantine v. TOWNSHIP OF BASS RIVER
967 A.2d 882 (New Jersey Superior Court App Division, 2009)
In Re Carter
924 A.2d 525 (Supreme Court of New Jersey, 2007)
DiProspero v. Penn
874 A.2d 1039 (Supreme Court of New Jersey, 2005)
Kershenblatt v. Kozmor
624 A.2d 1042 (New Jersey Superior Court App Division, 1993)
West Jersey Title & Guaranty Co. v. Industrial Trust Co.
141 A.2d 782 (Supreme Court of New Jersey, 1958)
State v. Downie
569 A.2d 242 (Supreme Court of New Jersey, 1990)
State v. Federanko
139 A.2d 30 (Supreme Court of New Jersey, 1958)
Gerofsky v. PASSAIC COUNTY SOC.
870 A.2d 704 (New Jersey Superior Court App Division, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
Mirza M. Bulur v. the New Jersey Office of the Attorney General, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mirza-m-bulur-v-the-new-jersey-office-of-the-attorney-general-njsuperctappdiv-2024.