Robert Cauvin v. Board of Education of the Township of North Brunswick

New Jersey Superior Court Appellate Division·Decided February 3, 2026·No. A-1098-24·Unpublished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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1098-24

ROBERT CAUVIN, Petitioner-Appellant,

v.

BOARD OF EDUCATION OF THE TOWNSHIP OF NORTH BRUNSWICK, MIDDLESEX COUNTY and NEW JERSEY DEPARTMENT OF EDUCATION, OFFICE OF STUDENT PROTECTION,

Respondents-Respondents.

Submitted January 13, 2026 – Decided February 3, 2026 Before Judges Firko and Perez Friscia.

On appeal from the New Jersey Commissioner of Education, Docket No. 195-7/22.

Schwartz Law Group, LLC, attorneys for appellant (Andrew L. Schwartz, on the briefs).

Methfessel & Werbel, PC, attorneys for respondent Board of Education of the Township of North

Brunswick (Eric L. Harrison, of counsel; Jeffrey R.

Merlino, on the brief).

Matthew J. Platkin, Attorney General, attorney for respondent Commissioner of Education (David L.

Kalisky, Deputy Attorney General, on the statement in lieu of brief).

PER CURIAM Appellant Robert Cauvin appeals from the November 4, 2024 final agency decision (FAD) of the Acting Commissioner of Education (Commissioner) finding he is permanently disqualified from working in any Department of Education (DOE) supervised educational institution pursuant to N.J.S.A. 18A:6- 7.1 because he was convicted of lewdness, N.J.S.A. 2C:14-4. Having reviewed the record, parties' arguments, and applicable law, we affirm.

I.

To give context to the issues presented on appeal, we summarize the facts and procedural history from the record. In October 1997, Cauvin was convicted of disorderly persons lewdness, N.J.S.A. 2C:14-4(a), in North Brunswick Municipal Court. He pled guilty and admitted to having consensual sex in a parked vehicle. The municipal court sentenced Cauvin to a $255 fine, which he paid.

In 1998, following his conviction, Cauvin was hired by the Scotch Plains-

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Fanwood Regional School District as a public school teacher and worked there for approximately five years. He obtained teaching certificates in "Elementary School Teacher" and "Teaching of Handicapped." In September 2003, the North Brunswick Township School District (North Brunswick School District) hired Cauvin as a tenured special education teacher. While Cauvin underwent employment background checks for both school districts, his lewdness conviction was not discovered.

On May 3, 2022, the DOE's Office of Student Protection (OSP) 1 emailed the North Brunswick School District's Superintendent, advising information was received that Cauvin had a lewdness conviction. The OSP's email stated that Cauvin's conviction permanently disqualified him from "serving in any position . . . with any educational institution under the supervision of the [DOE]." The OSP also notified Cauvin by letter that a municipal court record showed his lewdness conviction in 1997 and it "permanently disqualified" him from serving in a teaching position under the supervision of the DOE. The letter further stated Cauvin "[had fourteen] days from the date of [the] written notice to challenge the accuracy of [his] criminal history record."

1 We note the record and parties' merits briefs interchangeably refer to the DOE and OSP. For the purposes of consistency, we refer only to the DOE unless the action taken was directly by the OSP.

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The same day, the acting superintendent had Cauvin personally served with a letter informing him that the North Brunswick School District received a notice of his permanent disqualification from teaching based on his conviction, and, as a result, he was terminated from employment. On May 11, the North Brunswick Board of Education (Board) adopted a resolution retroactively terminating Cauvin's employment.

On July 21, 2022, Cauvin filed an application for emergent relief with the Commissioner. About two weeks later, the Administrative Law Judge (ALJ) heard the application and denied Cauvin's requested emergent relief. Thereafter, the Commissioner issued an order adopting the ALJ's decision and finding Cauvin "failed to demonstrate entitlement to emergent relief." The Commissioner also ordered that "th[e] case shall continue at the [Office of Administrative Law (OAL)]."

On August 26, 2022, Cauvin filed a three-count amended petition of appeal requesting the Commissioner find the following: the Board violated Cauvin's tenure rights because he was entitled to have tenure charges filed and further proceedings; the Board was required to reemploy him as a teacher and compensate his economic damages; Cauvin did not commit a "disqualifying crime or offense" requiring termination based on the Supreme Court's holding

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in State v. J.O., 69 N.J. 574 (1976); and the OSP was required to modify its records to indicate Cauvin "was not disqualified from holding a tenured full time teaching position."

On August 21, 2023, Cauvin and the DOE filed cross-motions before the ALJ for a summary decision. The parties also filed joint stipulations. Cauvin stipulated to the lewdness conviction but argued it resulted from his engaging in a consensual sexual act in his car that was parked in a private area. He argued the Board should be ordered to reinstate him as a teacher because his lewdness conviction was based on an act of "private consensual sexual activity" that should not be considered a disqualifying offense. He also contended legal precedent, prior arbitration awards, and earlier Commissioner decisions regarding "unbecoming conduct" mandated that his conviction should not be considered a disqualifying offense. Finally, he asserted the DOE was equitably estopped and barred under laches from determining he was disqualified.

The DOE argued Cauvin's lewdness conviction was a clear disqualifying offense under N.J.S.A. 18A:6-7.l mandating his termination. The DOE explained the OSP learned of the conviction after "a routine follow-up into an

A-1098-24

unrelated situation involving Cauvin." 2 In September 2023, the DOE filed a supplemental brief explaining that "Cauvin's [filed] expungement was denied."

On August 26, 2024, the ALJ issued an order accompanied by an initial decision granting Cauvin's motion for summary decision, denying the DOE's cross-motion for summary decision, and recommending the Commissioner reinstate Cauvin's employment. While the ALJ noted Cauvin's lewdness conviction was undisputed and that the conviction "resulted in his disqualification" under N.J.S.A. 18A:6-7.1, the ALJ nevertheless ordered Cauvin's employment reinstatement, effective May 3, 2022. The ALJ determined the DOE failed to provide Cauvin a hearing "to challenge the veracity, accuracy[,] and impact of the disqualifying criminal history." The ALJ reasoned Cauvin's reinstatement was required based on the following: "[J.O.] dictate[s] that individuals engaged in private consensual sexual activity could not be found guilty of indecent exposure, or committing an act of open lewdness" under N.J.S.A. 2C:14-4; Caucino v. Bd. of Trs., Tchrs.' Pension and Annuity Fund, 475 N.J. Super. 405 (App. Div. 2023) supports a finding that "an

2 We note the Commissioner's FAD and other documents reference Cauvin was involved in a separate incident. The Commissioner's FAD states that Cauvin was "on paid administrative leave following an unrelated November 2021 arrest." The separate incident is not relevant to this appeal.

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individual cannot be presumed guilty of any form of 'unbecoming conduct' if they were not employed as a teacher" at the time of the offense; and prior Commissioner's decisions and TEACHNJ arbitration awards support Cauvin's reinstatement. Additionally, he found the DOE was not "equitably estopped and barred" under the doctrine of laches from finding Cauvin's 1997 conviction permanently disqualified him from public school employment.

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