Nohemy Vargas v. Delia Orosco

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 7, 2026
DocketA-2357-24
StatusUnpublished

This text of Nohemy Vargas v. Delia Orosco (Nohemy Vargas v. Delia Orosco) 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
Nohemy Vargas v. Delia Orosco, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2357-24

NOHEMY VARGAS,

Plaintiff-Appellant,

v.

DELIA OROSCO and RAMON OROSCO,

Defendants-Respondents. __________________________

Submitted December 9, 2025 – Decided January 7, 2026

Before Judges Sumners and Susswein.

On appeal from the Superior Court of New Jersey, Law Division, Passaic County, Docket No. L-1276-22.

Anthony Scordo, PC, attorney for appellant (Anthony Scordo III, of counsel and on the briefs).

Methfessel & Werbel, attorneys for respondents (Paul J. Endler, Jr., on the brief).

PER CURIAM This case returns to us following a remand. Plaintiff appeals the renewal

of summary judgment dismissing her negligence complaint. We are constrained

to remand yet again with more specific instructions.

We presume the parties are familiar with the pertinent facts and procedural

history, which are fully recounted in our prior opinion. See Vargas v. Orosco,

No. A-3748-22 (App. Div. Aug. 8, 2024). Therefore, we need only briefly

summarize the circumstances leading to this latest appeal.

This lawsuit arises from an accident that occurred on May 30, 2020, in

which plaintiff was injured while descending the rear exterior staircase of her

apartment building, owned by defendant landlords. Plaintiff filed a negligence

complaint against defendants in May 2022. Following the completion of

discovery, the trial court granted summary judgment for defendants, reasoning

that because the staircase contained a latent defect unknown to both the tenant

and defendant landlords, defendants had no duty to inspect the area where

plaintiff fell.

Plaintiff appealed and we affirmed in part and remanded in part. Id. at 15.

The critical issue on appeal was, and remains, whether defendants owed a duty

of care to plaintiff. As we explained in our prior opinion, no tort liability is

imposed upon a landlord if a plaintiff has exclusive control over a premises and

A-2357-24 2 the landlord has no notice of the defect that caused plaintiff's injury. See Szeles

v. Vena, 321 N.J. Super. 601, 608 (App. Div. 1999) (concluding that a landlord

is not liable in a tort action for a condition on a leased premises when the tenant

has exclusive possession of the premises and the condition is unknown to the

landlord). In this instance, liability depends on whether the exterior staircase

where plaintiff fell is a common area of the multi-unit building. See Gonzalez

v. Safe & Sound Sec. Corp., 185 N.J. 100, 121 (2005) (restating landlord's duty

to keep common areas reasonably safe for tenants and their guests by conducting

reasonable inspections to discover "latent dangerous conditions").

We concluded that the trial court's decision granting summary judgment

in favor of defendants "is sound if the rear staircase is within plaintiff's exclusive

control." Vargas, slip op. at 11. However, because the trial court had not made

any finding on whether the rear staircase was a common area, we concluded that

summary judgment dismissal was premature. Id. at 11-12.

In reaching our conclusion, we highlighted the need for a "fact-sensitive

determination." Ibid. Accordingly, we instructed the trial judge "to determine

whether the rear staircase is a common area, applying the summary judgment

standard of viewing the record in a light most favorable to the party opposing

A-2357-24 3 summary judgment." Id. at 12. We did not, however, expressly require the trial

court to expand the existing record.

On remand, the trial court held a status conference and requested briefing

from the parties. Oral argument was held on November 1, 2024, and on February

21, 2025, the trial court rendered an oral decision, accompanied by a

supplemental order finding that the rear staircase was not a common area. The

court thereupon renewed the summary judgment order dismissing plaintiff's

complaint with prejudice.

The trial court reasoned that the staircase was not a common area based

on plaintiff's deposition testimony and counterstatement of facts that the

apartment was not properly registered with the city nor with the owner's

insurance company. The trial court explained,

It appears from the record that it may very well have been an illegal apartment, but it is clear from the record that the subject staircase was not for the common use or benefit of all the tenants of the premises. It was used by plaintiff to gain access to her attic unregistered apartment. It was not a communal staircase.

This second appeal follows. Plaintiff argues that the trial court violated

our order by failing to make additional findings of fact and by failing to expand

the record on remand.

A-2357-24 4 We reiterate and stress that the trial court did not violate our prior

instructions. The court dutifully made a finding on whether the staircase was a

common area of the apartment building. In doing so, however, the court did not

view the evidence in the light most favorable to plaintiff. Applying a de novo

standard of review, see Rios v. Meda Pharm., Inc., 247 N.J. 1, 13 (2021), we

conclude the evidence the trial court relied upon to grant summary judgment

was not dispositive on the issue of whether the staircase was used by other

tenants, see Brill v. Guardian Life Ins. Co. of America, 142 N.J. 520, 540 (1995)

(holding that the key inquiry on a motion for summary judgment is whether the

evidence presented, when viewed in the light most favorable to the non -moving

party, "[is] sufficient to permit a rational factfinder to resolve the al leged

disputed issue in favor of the non-moving party.").

Specifically, plaintiff testified at her deposition that she could access her

apartment from both the front interior staircase and rear exterior staircase.

Plaintiff further testified that the rear staircase had a landing on each floor. A

fair inference can be drawn from that testimony that the landings on each floor

had entry points into the other apartments so that the other tenants could likewise

access their units via the rear staircase. Whether that is so is a question that

remains unanswered.

A-2357-24 5 Stated another way, nothing in the record establishes that the tenants

living in "lawful" units either lack access to or have no need to use the exterior

staircase. We note plaintiff testified she could access her apartment via the

interior front staircase, suggesting that tenants in registered units might also use

both staircases if the exterior staircase landings gave access to their units.

We deem these unresolved fact-sensitive questions critical to resolving, at

the summary judgment stage, whether the staircase was under plaintiff's

exclusive control or instead could be classified as a common area for purposes

of the landlord's duty to inspect. We thus conclude the evidence relied on by

the trial court was insufficient to warrant summary judgment. Cf. Brill, 142 N.J.

at 540 (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Szeles v. Vena
729 A.2d 1064 (New Jersey Superior Court App Division, 1999)
Gonzalez v. Safe & Sound Security Corp.
881 A.2d 719 (Supreme Court of New Jersey, 2005)
Brill v. Guardian Life Insurance Co. of America
666 A.2d 146 (Supreme Court of New Jersey, 1995)

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