Timothy Scruggs v. Nj Transit Corporation

CourtNew Jersey Superior Court Appellate Division
DecidedMay 13, 2026
DocketA-2605-24
StatusUnpublished

This text of Timothy Scruggs v. Nj Transit Corporation (Timothy Scruggs v. Nj Transit Corporation) 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
Timothy Scruggs v. Nj Transit Corporation, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2605-24

TIMOTHY SCRUGGS,

Plaintiff-Appellant,

v.

NJ TRANSIT CORPORATION d/b/a NJ TRANSIT and ERIC GONZALEZ,

Defendants-Respondents. ____________________________

Submitted January 22, 2026 – Decided May 13, 2026

Before Judges Currier and Berdote Byrne.

On appeal from the Superior Court of New Jersey, Law Division, Camden County, Docket No. L-2797-24.

Joseph P. Grimes, LLC, attorney for appellant (Patrick J. Grimes, on the brief).

Anderson Law Office, LLC, attorneys for respondents (Jessica M. Anderson and Samuel K. Weathers, on the brief).

PER CURIAM Plaintiff Timothy Scruggs appeals from the trial court's March 14, 2025

order dismissing his complaint against defendants for failure to file a timely

complaint under the New Jersey Tort Claims Act (TCA), specifically N.J.S.A.

59:8-8(b) and 59:8-9.

On appeal, plaintiff contends the court erred in not applying the doctrine

of equitable tolling to permit the late complaint. However, the language of the

TCA is clear and unforgiving that "in no event may any suit against a public

entity or a public employee . . . be filed later than two years from the time of the

accrual of the claim." N.J.S.A. 59:8-9 (emphasis added). We affirm.

I.

On August 5, 2022, plaintiff boarded a bus in Philadelphia owned by

public entity NJ Transit Corporation (NJT) and operated by Eric Gonzalez, an

NJT employee. Plaintiff alleges that as he walked down the aisle, the bus

suddenly started moving forward, and he lost his balance and fell onto a broken

bus seat and then the floor, sustaining injuries.

Two years later, on August 5, 2024, plaintiff filed a complaint in the Court

of Common Pleas, in Philadelphia County, Pennsylvania, against defendants for

damages incurred as a result of defendants' negligent actions. The Pennsylvania

matter was still pending at the time of the briefing in this case.

A-2605-24 2 On September 24, 2024, plaintiff filed a complaint in the Superior Court

of New Jersey, alleging breach of express/implied warranty, violation of the

New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 to -227, and negligence in

failing to warn plaintiff of a dangerous condition.

Defendants moved to dismiss, arguing that plaintiff's claim was barred by

the statute of limitations under N.J.S.A. 59:8-9 and N.J.S.A. 59:13-5(b) of the

New Jersey Contractual Liability Act (CLA). The court denied the motion,

finding the statute of limitations was equitably tolled by the prior filing in

Pennsylvania.

Defendants moved for reconsideration, arguing that the trial court had

mistakenly applied the equitable remedy. The court found that the TCA was to

be strictly construed and there was no provision to permit equitable tolling.

Therefore, plaintiff's complaint was untimely as it was not filed within two years

after the cause of action accrued—the date of the accident. The court granted

defendants' motion for reconsideration and dismissed the complaint.

II.

On appeal, plaintiff asserts the equitable tolling doctrine applies to these

circumstances; the date of accrual of the action is not necessarily the date of the

A-2605-24 3 accident; and that defendants were not prejudiced by the late filing of the New

Jersey complaint. We disagree.

We review a trial judge's decision to grant or deny a motion for

reconsideration for an abuse of discretion, Branch v. Cream-O-Land Dairy, 244

N.J. 567, 582 (2021), which occurs when "a decision is 'made without a rational

explanation, inexplicably departed from established policies, or rested on an

impermissible basis,'" U.S. Bank Nat'l Ass'n v. Guillaume, 209 N.J. 449, 467-

68 (2012) (quoting Iliadis v. Wal-Mart Stores, Inc., 191 N.J. 88, 123 (2007)).

In contrast, our review of rulings of law and issues regarding the

applicability, validity or interpretation of laws, statutes, or rules is de novo. See

Kocanowski v. Twp. of Bridgewater, 237 N.J. 3, 9 (2019).

A.

We turn first to the statutes of limitations that govern this action and then

consider whether that limitations period may be tolled.

The TCA bars a claimant from recovering against a public entity or public

employee if "[t]wo years have elapsed since the accrual of the claim." N.J.S.A.

59:8-8(b); see also McDade v. Siazon, 208 N.J. 463, 474 (2011) (finding the

TCA is strictly construed to permit lawsuits only in circumstances expressly

delineated by the statute). Similarly, the CLA precludes a claimant from

A-2605-24 4 "forever" recovering against the State if "he fails to file suit within 2 years of

accrual of his claims . . . ." N.J.S.A. 59:13-5(b).

A plain reading of the respective statutes confirms that the statutory

language expressly precludes a claimant from asserting a cause of action more

than two years after the claim accrues. See State v. D.A., 191 N.J. 158, 164

(2005) ("The best indicator of [the Legislature's intent] is the statutory

language," thus "[i]f the plain language leads to a clear and unambiguous result,

then the interpretive process should end, without resort to extrinsic sources. ").

Plaintiff's claim accrued on August 5, 2022, the date of the accident. More

than two years later, on September 24, 2024, plaintiff filed a complaint in New

Jersey, after the statutes of limitations in both the TCA and CLA had elapsed.

Therefore, plaintiff is barred from asserting any claim against defendants.

Plaintiff attempts to circumvent the plain statutory language by invoking

the doctrine of equitable tolling, a remedy largely reserved for "very compelling

circumstances, where the interest of justice, morality and common fairness

dictate that course." Maltese v. Twp. of N. Brunswick, 353 N.J. Super. 226,

244-45 (App. Div. 2002). The argument is unavailing.

Equitable tolling is generally not "applied against the State to the same

extent as against private parties." Mills v. State, Dept. of Treasury, 435 N.J.

A-2605-24 5 Super. 69, 78 (App. Div. 2014) (quoting O'Neill v. State Highway Dep't of N.J.,

50 N.J. 307, 319 (1967)). The United States Supreme Court has held that

"limitations periods are 'customarily subject to equitable tolling,' unless tolling

would be 'inconsistent with the text of the relevant statute.'" Young v. U.S., 535

U.S. 43, 49 (2002) (citations and internal quotation marks omitted) (quoting

Irwin v. Dep't of Veterans Affairs, 498 U.S. 89, 95 (1990)).

Here, the language in the TCA is very clear in two different statutes that

there is no recourse to apply the doctrine of equitable tolling. N.J.S.A. 59:8-

8(b) states: "The claimant shall be forever barred from recovering against a

public entity or public employee if: . . . b. Two years have elapsed since the

accrual of the claim." (Emphasis added). N.J.S.A. 59:8-9 has equally strong

language: "[I]n no event may any suit against a public entity or a public

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