Sherri A. Affrunti v. Reed Smith LLP

CourtNew Jersey Superior Court Appellate Division
DecidedNovember 20, 2025
DocketA-2477-24
StatusPublished

This text of Sherri A. Affrunti v. Reed Smith LLP (Sherri A. Affrunti v. Reed Smith LLP) 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
Sherri A. Affrunti v. Reed Smith LLP, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2477-24

SHERRI A. AFFRUNTI, APPROVED FOR PUBLICATION Plaintiff-Appellant, November 20, 2025 APPELLATE DIVISION v.

REED SMITH LLP,

Defendant-Respondent. _________________________

Argued October 7, 2025 – Decided November 20, 2025

Before Judges Sumners, Susswein, and Chase.

On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Mercer County, Docket No. L-2297-20.

Sherri A. Affrunti, appellant, argued the cause pro se.

Sean P. Joyce argued the cause for respondent (Carmagnola & Ritardi, LLC, attorneys; Sean P. Joyce, of counsel and on the brief; Casey L. Murphy, on the brief).

The opinion of the court was delivered by

SUMNERS, JR., C.J.A.D. Plaintiff Sherri A. Affrunti filed a Law Division complaint seeking

compensation claims against her former employer, defendant Reed Smith,

LLP, under provisions of the Diane B. Allen Equal Pay Act (Allen Act or

statute), L. 2018, c. 9 (codified as amended in various sections of N.J.S.A.),

the New Jersey Law Against Discrimination (LAD), N.J.S.A. 10:5-1 to -50,

and the New Jersey Wage Payment Act (WPA), N.J.S.A. 34:11-4.1 to -4.14.

On leave to appeal, Affrunti raises issues of first impression under the Allen

Act arising from the motion court's omnibus order.

The first issue concerns the scope of damages resulting from the Allen

Act's expansion of the lookback period for claims under the LAD and WPA

from two years to six years. The motion court, citing the two-part test to

determine whether a statute is applied retroactively or prospectively set forth

in our Supreme Court's recent decision in Maia v. IEW Constr. Grp., 257 N.J.

330 (2024), applied the statute prospectively; thus, its order limited Affrunti's

damages to the period from July 1, 2018 (the Allen Act's effective date) to

January 11, 2019 (the date her employment ended with Reed Smith).

We agree with the motion court that, based on Maia, the Allen Act

should be applied prospectively. We nonetheless conclude the court incorrectly

applied this prospective approach in its order. The Allen Act's six-year

lookback period applies to claims arising after its effective date but does not

A-2477-24 2 eliminate the prior two-year lookback period under the LAD and WPA that

existed prior to the statute. Applying the LAD's two-year lookback period,

Affrunti should be allowed to pursue damages from December 18, 2020 (the

date she filed her complaint) to December 18, 2018––not July 1, 2018 to

January 11, 2019, as the motion court held. We do not review claims of

continuing violations occurring prior to December 18, 2018.

The second issue on appeal is whether the discovery of comparator

employee compensation data authorized under the Allen Act should be limited

to July 1, 2018 through January 11, 2019 due to the motion court's prospective

application of the statute. We conclude the motion court erred in limiting

discovery to this time period. We determine that the discovery period should

be from December 18, 2018 to December 18, 2020, corresponding to the two-

year lookback period. Any expansion of the period based on continuing

violations is not reviewed in this appeal.

The third issue on appeal is whether the Allen Act's provision that

"[c]omparison of wage rates shall be based on wage rates in all of an

employer's operations or facilities" should be interpreted to apply to all of an

employer’s operations, whether in-state or nationwide. We conclude the court

erred in limiting comparator employee compensation data to Reed Smith's

New Jersey office. The Allen Act's text, legislative history, and relevant

A-2477-24 3 agency interpretations support broad discovery of the comparator employee

compensation data provision, thus permitting Affrunti to obtain Reed Smith's

national comparator data.

The fourth issue on appeal is whether the discovery of comparator

employee compensation data should cover January 1, 2006 (the approximate

date Reed Smith promoted Affrunti to Non-Equity/Fixed Shared Partner

(FSP)) to January 11, 2019. We conclude the court erred in restricting

discovery to July 1, 2018 through January 11, 2019. Affrunti is entitled to

discovery from January 1, 2006 to January 11, 2019, as she is permitted broad

discovery of national comparator employee compensation data.

I.

A.

Affrunti began her employment as an associate attorney with Reed Smith

in 2002. Reed Smith is headquartered in Pennsylvania with thirty-two offices

worldwide, eighteen of which are in the United States. Affrunti was promoted

to FSP on or about January 1, 2006. She worked primarily in the Princeton

office but also had an office in Philadelphia and regularly worked in New

York.

On January 11, 2019, Affrunti resigned from her employment as an FSP

with the firm contending gender discrimination in being "dramatically

A-2477-24 4 underpaid . . . compared to male FSPs who performed substantially similar

work." She received her last two paychecks on January 25, 2019 and March

16, 2019.

B.

On December 18, 2020, Affrunti filed a Law Division complaint 1 against

Reed Smith, alleging disparate pay in violation of the EPA, gender

discrimination in violation of the LAD, and violation of the WPA. 2 The

parties consented to a protective order requiring confidentiality of discovery.

In February 2023, a case management order required Reed Smith to

produce comparator employee compensation data for FSPs in its Princeton

office from January 1, 2013 through December 31, 2018. Six months later,

another case management order extended discovery and preserved Affrunti's

right to "re-file her application to compel production of all comparator

employee compensation discovery."

In July and August of 2024, the parties filed multiple motions

concerning the limits of discovery and damages. On November 24, the court

1 Affrunti was initially represented by counsel but represented herself as of July 17, 2024. 2 The parties and the motion court interchangeably refer to the WPA and the Wage Payment Law (WPL), N.J.S.A. 34:11-4.1 to -4.14. For consistency, we refer only to the WPA.

A-2477-24 5 entered a four-part omnibus order, granting Reed Smith's motions and denying

Affrunti's motion and cross-motion.

We summarize the court's reasoning as set forth in its statement of

reasons. First, the court granted "[Reed Smith's] motion to limit [Affrunti's]

damages, narrowing [Affrunti's] discovery of comparator employee

compensation information to the time of the effective date of the [Allen Act],

through [Affrunti's] departure from the firm, from July 1, 2018, to January 11,

2019." The court barred discovery beyond the Allen Act's effective date

because it determined that under the two-part test applied by the Supreme

Court applied in Maia, 257 N.J. at 349, "the [Allen Act] is to be applied

prospectively, and thus the [six-year] lookback period can only extend" as far

back as the statute's effective date. Regarding the first part of the test ––

whether the Legislature explicitly or implicitly intended the statute to be

retroactive, ibid.

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Sherri A. Affrunti v. Reed Smith LLP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sherri-a-affrunti-v-reed-smith-llp-njsuperctappdiv-2025.