On June 25, 2025, Plaintiff Yao Ren was driving his car on Route 124 at its intersection with Morris Ave. in Millburn and came to a stop at an intersection intending to turn left on Morris Ave. According to his testimony, when the signal turned green, he proceeded into the intersection and struck the rear bumper of the car driven by defendant David Coelho. Ren claimed he had a green left-turn arrow while Coelho had a red light and, with his green light, the right of way in making a left turn. He claimed Coelho’s left-rear bumper stuck out and caught his right bumper, tearing it off. Ren sued Coelho in small claims court for his property damage. When he lost in a non-jury trial, Ren requested the court reconsider its findings. The issue in Yao Ren v. Coelho, 2026 N.J. Super. Unpub. LEXIS 2152 (App. Div. Oct. 1, 2026) was whether the trial court abused its discretion in denying plaintiff’s motion for reconsideration under Rule 4:49-2.
At trial, the presiding judge reviewed photos of the intersection that showed the lanes in which the parties traveled, the police report that described the facts of the accident (but placed no fault on either party and issued no summonses), and the parties’ testimony, and found Ren caused the accident. With this, the court dismissed the complaint. Ren filed a motion for reconsideration, claiming the court did not review all of the evidence. The court denied that motion. Ren appealed.
At the outset, the Appellate Division advised that its review of a bench trial was limited, giving deference to the court’s determinations based on oral testimony and written evidence and biding on appeal when supported by the “adequate, substantial, and credible evidence.” Here, the Court found the lower court’s reliance on the testimony and evidence was reasonable and should not be disturbed. Further, it noted that a motion for reconsideration, another process in which the appeals court permits the trial court broad discretion, requires the moving party to specifically state the basis for their motion and controlling case law on which it is made. However, in a much more strict manner, the Appellate Division held that reconsideration should only be granted upon a “palpably incorrect and irrational basis” or when it was obvious the court failed to consider critical, competent evidence. The Appellate Division found that the trial court satisfied its light burden by noting Ren failed to point to any evidence he believed the trial court erred or overlooked and that the court had reviewed all evidence at trial. In doing so, the Court found no grounds to overrule the trial court’s denial of the motion for reconsideration as well.
This matter underscores the standards at which New Jersey’s Appellate Division defers to the state’s trial courts on bench trials and motions for reconsideration. Because those two trial court functions are fact-intensive and delicate, appellate courts will defer to their findings unless the trial record is devoid of evidence supporting its conclusions or its rulings are clearly in error. As a result, the Appellate Division must stay away from inserting its judgment for that of the trial court.
