Monika Patel v. Public Service Enterprise Group, Inc.

New Jersey Superior Court Appellate Division·Decided June 25, 2026·No. A-1948-24·Unpublished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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1948-24

MONIKA PATEL AND ALPESH PATEL,

Plaintiffs-Appellants,

v.

PUBLIC SERVICE ENTERPRISE GROUP, INC., 1

Defendant-Respondent,

and

NEW JERSEY TURNPIKE AUTHORITY/GARDEN STATE PARKWAY, AND ARYAN A. PATEL,

Defendants. ________________________

Argued March 18, 2026 – Decided June 25, 2026

Before Judges Berdote Byrne and Jablonski.

1 Public Service Electric & Gas Company, a subsidiary of Public Service Enterprise Group Incorporated. On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. L-0832-22.

Anthony M. Juliano argued the cause for appellants (Brach Eichler LLC, attorneys; Anthony M. Juliano, on the briefs).

Alexandra F. Grant argued the cause for respondent (PSEG Services Corporation, attorneys; Alexandra F. Grant, on the brief).

PER CURIAM

Plaintiffs Monika Patel and Alpesh Patel appeal from the Law Division's

February 28, 2025, decision granting defendant Public Service Electric and Gas

Company's ("PSE&G") summary judgment motion and dismissing their

complaint. Because the trial court's factual findings were adequately supported

by the record, and the judge correctly applied well-established law under the

summary judgment standard, we affirm.

I.

We derive the facts and procedural history from the motion record. In

November 2020, plaintiff Monika Patel was injured when she was a passenger

in a vehicle that was driven by her son on the Garden State Parkway. The

accident occurred when the vehicle contacted a downed utility wire, which

caused it to roll onto its side. In a crash investigation report, the police noted

that the driver allegedly "did not see [the wire in the road] until the last second."

A-1948-24 2 The wire in question, along with related infrastructure, was owned by

PSE&G. In discovery, PSE&G employees testified that the cause of the accident

was not definitively known, though possible contributing factors such as rain,

weather, or wildlife could not be ruled out. Inspection records revealed PSE&G

performed visual and thermographic inspections on the equipment in 2018,

2019, and July 2020, with the last inspection having taken place approximately

three months before the accident. No issues were noted in the section of the

equipment where the accident occurred. PSE&G learned of the downed wire

only after being notified by the police that an accident occurred. Plaintiffs

retained James Orosz, P.E., an expert who concluded that PSE&G's lack of

compliance with certain regulatory standards caused the accident.

Plaintiffs sued PSE&G, New Jersey Turnpike Authority ("NJTA"), and

their son, Aryan Patel, seeking compensation for Monika Patel's injuries. NJTA

was voluntarily dismissed without prejudice and plaintiffs settled with Aryan

Patel. As the sole remaining defendant, PSE&G moved for summary judgment.

PSE&G primarily argued that since it lacked notice of the purported

dangerous condition, it could not be liable. Plaintiffs defended those assertions

with a host of arguments. In an oral opinion, a Law Division judge granted the

application and concluded:

A-1948-24 3 The issue here is obviously one of notice and either, in fact, . . . [p]laintiff has the burden of proof to show that the conditions as existed are either . . . [d]efendant either knew or should have, or had reasonable [knowledge of the conditions and that they were] there for an unreasonable length of time that [defendant] should have been able to find out this particular issue.

I don't find that the notice aspects have been satisfied. The fact that there was a regulation violation of the administrative code does not create a prior right of action in this case.

This is not a mode of operation case, because [the] . . . hanging down wire does not fall within that category. I think that . . . [p]laintiffs' expert is a net opinion. This is not a res ipsa loquitur case, because the conditions that existed were not in exclusive control of . . . [d]efendant nor does the fact that they bespeak negligence in and of themselves.

Obviously, the driver of the car clearly has an obligation to make reasonable observations, nor is this a common knowledge issue, because apparently this wire fell down in the middle of a storm, in the middle of the night.

....

Therefore[,] the [c]ourt does not find . . . [p]laintiff can sustain the burden of proof as a matter of law in this matter, and therefore the motion for summary judgment is granted.

A-1948-24 4 Plaintiffs also alleged spoliation of evidence, arguing PSE&G allowed the

NJTA to remove the downed wire and failed to produce inspection documents

during discovery. The motion judge disagreed, holding:

And also the argument . . . with regard to spoliation, there's no record in fact that there was any request at the time of the accident or shortly thereafter that counsel requested that any evidence be preserved pursuant to the rule.

On appeal, plaintiffs contend: (1) they are not required to prove a

regulatory violation to establish negligence; (2) they do not need to demonstrate

that PSE&G had notice of the dangerous condition; (3) the opinion of plaintiffs'

expert is not impermissibly conclusory; (4) expert testimony is not necessary to

establish PSE&G's negligence; and (5) PSE&G spoliated evidence and failed to

produce relevant documents.

After considering the record in light of plaintiffs' claims, we affirm the

motion judge's decision substantially for the reasons set forth in his oral opinion.

We add these explanatory comments as to central issue of notice.

II.

Our review of a trial court's grant of a motion for summary judgment is

de novo. Christakos v. Boyadjis, 262 N.J. 447, 467 (2026). We consider

"whether the competent evidential materials presented, when viewed in the light

A-1948-24 5 most favorable to the non-moving party, are sufficient to permit a rational

factfinder to resolve the alleged disputed issue in favor of the non-moving

party." Statewide Ins. Fund v. Star Ins. Co., 253 N.J. 119, 125 (2023) (internal

quotation marks omitted) (quoting Brill v. Guardian Life Ins. Co. of Am., 142

N.J. 520, 540 (1995)). A motion for summary judgment will be granted if "the

pleadings, depositions, answers to interrogatories and admissions on file,

together with the affidavits, if any, show that there is no genuine issue as to any

material fact challenged and that the moving party is entitled to a judgment or

order as a matter of law." Green v. Monmouth Univ., 237 N.J. 516, 529 (2019)

(internal quotation marks omitted) (quoting R. 4:46-2(c)).

"'The fundamental elements of a negligence claim are [(1)] a duty of care

owed by the defendant to the plaintiff, [(2)] a breach of that duty by the

defendant, [(3)] injury to the plaintiff proximately caused by the breach, and

[(4)] damages.'" Coleman v. Martinez, 247 N.J 319, 337 (2021) (quoting

Robinson v. Vivirito, 217 N.J. 199, 208 (2014)). Plaintiffs bear the burden to

establish each element. Ibid. (citing Polzo v. Cnty. of Essex, 196 N.J. 569, 584

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