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No Denial of Access Under OPRA Where Request Submitted to Incorrect Entity

On April 20, 2023 the New Jersey Appellate Division decided an Open Public Records Act (“OPRA”) matter in the case of Owoh v. City of Camden, 2023 N.J. Super. Unpub.  LEXIS 597 (App. Div. Apr. 20, 2023).  The Appellate Division determined the City of Camden (“City”) did not deny access to requested police records and the City was not obligated to retrieve the records from the County of Camden (“County”) a separate public entity.  The firm successfully represented the City on appeal.

Plaintiff-Respondents, Rotimi Owoh, o/b/o African American Data and Research Institute, and Baffi Simmons (“Owoh”) filed an OPRA request with the City back in November of 2018 for various police department records.  The City directed the requestor to the proper custodian of the requested records, the County, as the City had not had its own police force since 2013 when the County assumed all police services for the City.  The requestor filed a denial of access complaint with the Government Records Council (“GRC”) and the GRC determined the City denied access to the requested records, was obligated to retrieve the records from the County because of the Police Services Agreement between the City and the County and awarded attorneys’ fees to Owoh.

The City appealed the GRC’s determination to the Appellate Division on the basis Owoh did not serve the proper custodian with the request, the City was not the custodian of the records and the City could not be under an obligation to retrieve records from a separate public entity.  The Appellate Division found in the City’s favor in all regards and reversed the GRC’s decision finding the City denied Owoh access to the requested records.  The Appellate Division determined the City did not unlawfully deny access to records which were made and maintained by the County and that once the City received the request properly meant for the County, the City’s Custodian complied with the statute by directing the requestor to the proper County Custodian.  Importantly, the Appellate Division vacated the award of attorneys’ fees to Owoh.

Appellate Division Defines Arbitrator’s Authority Regarding Tenure Charges

By: Erika Vasant, Law Clerk

Editor: Sanmathi (Sanu) Dev, Esq.

On August 25, 2022, in Sanjuan v. School District of West New York, the New Jersey Appellate Division in a published decision addressed the scope of an arbitrator’s authority under N.J.S.A. 18A:6-16 regarding tenure charges against a teacher. The Appellate Division held that an arbitrator may uphold a suspension without pay if a teaching staff member’s conduct was unbecoming. However, arbitrators lack the authority to demote teaching staff members from their positions.

In this case, the West New York Board of Education (“Board”) demoted plaintiff Sanjuan from assistant principal to fourth-grade teacher for inappropriate conduct. Sanjuan attended a high school activity and fell down a flight of stairs. After the fall, she reached into her purse, removed a piece of paper, and walked halfway up the stairway to place it on one of the steps. She then returned to the bottom of the stairs. The incident was caught on camera. The next morning, the benefits coordinator contacted her, and she confirmed that she fell after seeing the piece of paper on the stairs. The school district found that she manipulated the scene, allowed a false incident report to be made, and engaged in insurance fraud. 

The Board approved tenure charges against Sanjuan in accordance with the Tenure Employees Hearing Law (“TEHL”), suspending her for 120 days without pay. After reviewing Sanjuan’s response, the Commissioner of Education found that Sanjuan’s conduct warranted “dismissal or reduction in salary” and referred the case to an arbitrator in accordance with N.J.S.A. 18A:6-17.1. The arbitrator found that Sanjuan’s conduct warranted retention of her tenure but as a fourth grade teacher (instead of assistant principal) without back pay. Sanjuan sought to vacate the arbitration reward, be reinstated as assistant principal, and receive the lost wages. The trial court then denied her relief, and affirmed the entire arbitration award. Sanjuan appealed.

On appeal to the New Jersey Appellate Division, Sanjuan argued that the arbitrator exceeded his authority and that since her tenure was not terminated, she should receive back pay during her suspension. The Appellate Division disagreed and noted that the trial court upheld the Board’s determination of Sanjuan’s conduct as unbecoming. Accordingly, under N.J.S.A. 18A:6-14, the arbitrator’s determination that Sanjuan was not permitted to receive back pay was authorized. However, the Appellate Division found that the arbitrator exceeded his authority in demoting Sanjuan, because it deviated from the disciplinary action specified in N.J.S.A. 18A:6-10. The statute provides that tenure charges against a teaching staff member may only include either termination or depriving him or her of salary – not demotion.

As a result, the Appellate Division vacated the trial court’s order and remanded the case to the arbitrator to “reconsider the penalty of termination.”

Students’ Initials Can Be Redacted in Response to an OPRA Request

By: Angela Reading, Law Clerk

Editor: Sanmathi (Sanu) Dev, Esq.

On September 29, 2022, the New Jersey Appellate Division in L.R. o/b/o J.R. v. Cherry Hill Board of Education issued a published decision affirming a ruling by the Superior Court of New Jersey, which held that a district could redact all parent and student information, including initials, when providing settlement agreements in response to an Open Public Records Act (“OPRA”) request.

In this case, the plaintiff, the mother of a student with a disability, made an OPRA request to the defendant Cherry Hill Board of Education (“Board”) for all settlement agreements in which the Board was named as a defendant and a student and/or their parent was named as a plaintiff. The Board provided the records sought but redacted all parent and student information, including initials. The plaintiff sued, asserting that the Board violated OPRA and improperly withheld information by redacting all personally identifiable information (“PII”).

In January 2015, the trial court granted the Board’s cross-motion for summary judgment, finding the initials were exempt from disclosure under the Family Educational Records and Privacy Act (“FERPA”) and the New Jersey Pupil Records Act (“NJPRA”). The plaintiff appealed and the matter was stayed pending the resolution of L.R. I and L.R. II. Following L.R. II, a special master adjudicated the Board’s motion to dismiss for failure to state a claim and recommended the court grant the motion. Plaintiff appealed the recommendation, and the trial judge affirmed, adopting the master’s findings of fact and conclusions of law.

The discrete issue raised on appeal was whether the Board should have redacted the PII altogether as opposed to leaving the initials intact. The plaintiff asserted the trial court erred by relying on the 2015 summary judgment decision and misunderstood the holdings of L.R. I and L.R. II.

The Appellate Division upheld the trial court’s decision, finding that using students’ initials is insufficient to protect identity as required by FERPA and NJPRA. The Court further held that just because the information may ordinarily be available to and accessible by the public — as legal submissions filed with the court — that does not “ipso facto mean that no legitimate privacy interest predominates.”

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Court Dismisses Pothole Case against County

Plaintiff Luz Cruz (“Cruz”) tripped and fell in a pothole when crossing River Avenue in Camden, New Jersey. She broke her fifth metatarsal of her left foot and sued the County of Camden for her injuries. In Cruz v. Camden County, 2019 N.J. Super. Unpub. LEXIS 385 (App. Div. Feb. 19, 2019), one of the issues was whether the County had prior notice of the pothole.

Cruz and her friend drove a U-Haul truck to pick up a couch in an apartment on River Avenue, a County owned road. They parked the truck across the street from the apartment. They did not see a pothole while walking to the apartment. As they were carrying the couch to the truck, Cruz stepped into the pothole in the middle of the road and fell. About two months after the accident, plaintiff’s expert measured the pothole as about 18 inches in length, 6 inches wide, and 3 inches deep.

The County had no prior notice of this pothole’s existence. The County’s Department of Public Works (“DPW”) employees are tasked with looking for potholes and repair them upon their discovery. In addition, the County has a dedicated phone line and email address for complaints as to potholes or other road problems. Also, police, fire, and public safety personnel will report road problems. However, no complaints had been called in as to this particular pothole or on this block of River Avenue in the 10 years before the accident.

As for constructive notice, plaintiff was unable to establish how long the pothole had been present. Cruz had been there the year before at the same address and did not notice the pothole. Plaintiff retained an expert who did not determine or estimate when the pothole had formed.

The County filed a motion for summary judgment, arguing that the plaintiff had failed to show that the County had actual or constructive notice of the pothole, as required under the Tort Claims Act to prove a claim against a public entity for a dangerous condition. The trial court agreed and granted the motion, finding that the plaintiff was unable to prove any time frame for the pothole or that the pothole was “of such an obvious nature that the public entity, in exercise of due care, should have discovered the condition and its dangerous character.”

The plaintiff appealed to the Appellate Division, arguing that the County had actual or constructive notice of the pothole and failed to repair it and that the County’s failure to maintain a major County road was palpably unreasonable. The Appellate Division rejected these arguments and upheld the trial court’s decision.

The Appellate Division noted that public entity liability is restricted under the Tort Claims Act. For liability to attach for an injury caused by a dangerous condition, a plaintiff must establish that a public entity “had actual or constructive notice of the dangerous condition” in “a sufficient time prior to the injury to have taken measures to protect against the dangerous condition.”

The Court agreed with the trial court that there was no actual notice. The question was whether the plaintiff had proven that the County had constructive notice of the pothole. To prove constructive notice, the plaintiff must establish “that the condition existed for such time that the [County], in exercising due care, should have discovered the condition and its dangerous condition.” The Appellate Division found that was no evidence of how long the pothole existed before the accident. Hence, the plaintiff could not prove constructive notice either. Without such notice, the Court found that the plaintiff’s claim fails.

The Appellate Division also found that the County’s inaction in repairing River Avenue was not palpably unreasonable. The plaintiff failed to show that it was not palpably unreasonable for the County to fail to fix a pothole that was harmless for a vehicle to pass over to prevent a pedestrian to trip over in a portion of the road that was not a designated crosswalk.

This case is illustrative of the difficulty that plaintiffs face in pursuing pothole claims against public entities. Because potholes can pop up in a day, depending on weather conditions, unless the public entity has actual notice of the pothole, it can be very difficult for a plaintiff to prove constructive notice.

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Betsy G. Ramos, Esq. is a member of the firm’s Executive Committee and Co-Chair of the Litigation Group. She is an experienced litigator with over 25 years’ experience handling diverse matters. Her practice areas include tort defense, insurance coverage, Tort Claims Act and civil rights defense, business litigation, employment litigation, construction litigation, estate litigation and general litigation.

Appellate Division Limits Attorneys’ Fees in OPRA Case

By:  Sanmathi (Sanu) Dev, Esq.

On November 27, 2017, the New Jersey Appellate Division in Kennedy v. Montclair Center Corporation Business Improvement District issued an unpublished decision in which it determined that the Open Public Records Act (“OPRA”) does not entitle a plaintiff to attorneys’ fees after the public agency satisfied his document request.

Scott Kennedy made an OPRA request to the Montclair Center Corporation Business Improvement District (“Montclair Center”). Not having received an adequate response, Kennedy filed suit against the Montclair Center alleging that it had no OPRA custodian, had no OPRA request form, and charged excessive copying costs in violation of OPRA. After the lawsuit was filed, the Montclair Center provided the requested documents to Kennedy but maintained its position that it was not a public agency subject to OPRA. In a separate action decided in 2014, the Appellate Division ruled that the Montclair Center was a public agency subject to OPRA.[1]

On remand, the trial court addressed the issue of attorneys’ fees. Kennedy argued that he was a prevailing party entitled to attorneys’ fees for both receiving the documents from the Montclair Center and for obtaining a decision from the Appellate Division that the Montclair Center was a public agency. The trial court disagreed and only awarded Kennedy counsel fees through the receipt of the documents. Kennedy then appealed to the Appellate Division.

The Appellate Division disagreed with Kennedy and affirmed the trial court. In analyzing N.J.S.A. 47:1A-6, the Appellate Division reasoned that the fee-shifting provision of OPRA only applies to successful challenges regarding access to public records. Further, the right to counsel fees only belongs to an OPRA requestor. The Appellate Division explained that once a party receives full access to requested documents, the party is no longer considered a requestor. In short, a party that chooses to pursue additional relief after obtaining access, even if the relief sought is under OPRA, is no longer an OPRA requestor. Thus, when Kennedy pursued his lawsuit against the Montclair Center after it provided him with the documents, he was no longer a requestor entitled to counsel fees.

[1] Kennedy v. Montclair Ctr. Corp. Bus. Improvement Dist., 2014 N.J. Super. Unpub. LEXIS 1654 (App. Div. June 24, 2014)

Frivolous Fee Award Against Pro Se Plaintiffs Limited by New Jersey Appellate Division

Under New Jersey law, fees may be obtained against attorneys for the filing of a frivolous lawsuit based upon a court rule, Rule 1:4-8. Attorneys fees for the filing of a frivolous pleading may be obtained against a party based upon a statute, N.J.S.A. 2A:15-59.1. The published decision of Tagayun v. AmeriChoice of New Jersey, 2016 N.J. Super. LEXIS 127 (App. Div. Sept. 20, 2016), demonstrates the difficulty in successfully obtaining attorneys fees under this statute.

This case involved a claim by Dr. Tagayun and Robert S. Mandell, her husband and office manager, against defendant AmeriChoice, contesting her termination as a provider. The Plaintiffs filed their complaint pro se. AmeriChoice contended that the complaint was frivolous because the contract between the parties provided for arbitration of all disputes and, as to Mandell, his claim was frivolous because he was not a party to the contract. Thus, he had no standing to enforce the contract.

The trial judge dismissed the original complaint without prejudice, sending the claim to arbitration as to Tagayun. The judge dismissed Mandell’s claim due to lack of standing. However, the plaintiffs filed an amended complaint, which was substantively the same, except they added the law firm and individual attorneys representing AmeriChoice as additional named defendants.

The trial court judge concluded that both the original complaint and the amended complaint were frivolous. As a sanction for the filing of these frivolous pleadings, the trial judge awarded fees in the amount of $10,073.20 for the filing of the original complaint and $6,599.40 for the filing of the amended complaint. The plaintiffs appealed both fee awards to the Appellate Division.

To award fees under N.J.S.A. 2A:15-59.1, the court must find that the claim was pursued “in bad faith, solely for the purpose of harassment, delay or malicious injury” or that the non-prevailing party knew or should have known it “was without any reasonable basis in law or equity and could not be supported by a good faith argument for an extension, modification or reversal of existing law.”

There was no evidence that the complaints were filed for the purpose of harassment, delay or malicious injury. Rather, the defendants argued that they were frivolous because they lacked a legal basis, i.e., the contract contained an arbitration clause which mandated all disputes would go to arbitration and Mandell lacked standing.

However, the Appellate Division found that the complaint by Tagayun was not frivolous because  of the Supreme Court’s decision in Atalese v. U.S. Legal Services Group, L.P., 219 N.J. 430 (2014), holding that arbitration provisions which did not contain a knowing waiver of the constitutional right to a jury trial were unenforceable. Based upon Atalese, even though Tagayun’s complaint was dismissed, it was deemed not frivolous.

As to Mandell, the court noted that it was clear that he was not a party to the contract and, thus, the trial court properly dismissed his claim. However, the Appellate Division found that his claim was not frivolous. Although his claim may have been ill-founded, it was not filed in bad faith. He had presented an argument that he was a third party beneficiary. Although the court declined to accept that argument, it showed that an award of sanctions was not merited.

Just because a party loses their case, it does not mean that sanctions for frivolous litigation should be imposed. The Appellate Division emphasized that “the term frivolous should not be employed broadly or it could limit access to the court system.”

However, the Appellate Division did find that the award of fees for the filing of the Amended Complaint was merited. By that point in the litigation, Tagayun had been advised by the court that her claim had to be arbitrated and Mandell had been told that he had no standing to assert a claim under the contract. Thus, the Appellate Division did affirm the award of fees as to the amended complaint.

This case demonstrates the difficulty in obtaining fees for the filing of a frivolous lawsuit against a pro se party. The frivolous lawsuit statute has a more stringent standard to meet than pursuing fees against an attorney under the court rule, Rule 1:4-8. If there is at least a colorable argument as to the basis of the complaint filed by a pro se party, the court will likely find that it was not filed in bad faith and, hence, no award of fees would be merited.

Provision in Employment Contract Limiting Employee’s Ability to Sue Third Party Found Unenforceable by NJ Court

Plaintiff Philip Vitale was injured while working as a security guard for Allied Barton Security Services, LLC (“Allied Barton”), which contracted with defendant Schering-Plough Corporation to provide security services to its facilities. Plaintiff had signed a disclaimer, waiving his right to sue any of Allied Barton’s customers to which he may be assigned. In the published decision of Vitale v. Schering-Plough Corp., 2016 N.J. Super. LEXIS 114 (App. Div. Aug. 22, 2016), the Appellate Division held that this waiver was unenforceable.

Plaintiff had been working as a security guard with Allied Barton for 4 years before the accident. While he was assigned to many of defendant’s work sites, he was never directly employed by defendant Schering-Plough, which had its own in-house security employees. He had been promoted to the position of field manager, supervising Allied Barton’s security guards who worked at defendant’s sites.

This accident occurred when plaintiff was going down the stairs of the guardhouse basement. Apparently, he tripped over a bag of ice melt and fell down the stairs. Plaintiff claimed to have suffered injuries to his neck, shoulder, and lower back, as well as cognitive difficulties.

The matter was tried before a jury, which awarded $900,000 in damages. Defendant appealed on the basis that the court erred in refusing to grant it summary judgment based upon the contractual waiver to sue signed by the plaintiff at the inception of his employment. The defendant argued that this waiver was valid and enforceable.

When plaintiff began his employment with Allied Barton, he signed a “Worker’s Comp Disclaimer.” Per this disclaimer, the plaintiff acknowledged that state Workers’ Compensation statutes covered his work-related injuries. Further, he agreed that, as a result, and in consideration of Allied Barton offering him employment, he would waive and release any and all rights to make a claim or commence a lawsuit from or against any customer of Allied Barton to which he may be assigned, “arising from or related to injuries which are covered under the Workers’ Compensation statutes.”

The Appellate Division found that enforcement of this waiver would be against public policy, as well as not “congruent” with the intent of the Workers’ Compensation Act for several reasons. First, the plaintiff would have been unaware of the risks he was taking because, when he signed the disclaimer, he did not know the identity of Allied Barton’s clients. Thus, he could not know the working conditions he might encounter while working at the facilities of Allied Barton’s clients

Second, this disclaimer created a disincentive for the defendant Schering-Plough to maintain a safe working condition for contractors working on its premises. Because the defendant would now be insulated from liability due to this disclaimer, it had a reduced incentive to maintain a safe work place for its contractors.

Third, to the extent this waiver would be waiving the plaintiff’s rights to recover for reckless or intentional conduct, the disclaimer is against public policy. The defendant argued that this disclaimer only waived claims covered by the Workers’ Compensation Act (“the Act”) and claims of reckless and intentional misconduct are not covered by the Act. However, the Appellate Division stated that it did not view the Act’s “intentional wrong” exception as broadly as the defendant suggested. Conduct that could be viewed as reckless or intentional under general tort law could result in injuries covered by the Act and, hence, unlawfully waived by the disclaimer.

Last, the Appellate Division pointed out that enforcement of this disclaimer would be contrary to the Act because it would not permit the plaintiff to pursue the defendant as a joint employer, who could be liable to pay him workers’ compensation benefits. New Jersey recognizes that an employee may have two employer, both of which may be liable for workers’ compensation (the “joint employer doctrine”). There is a 3 part test developed to establish such a special-employment relationship with the “joint employer.”

The court pointed out that the type of relationship between Allied Barton and the defendant has been long recognized. Further, the court had previously recognized the concept of joint employment in a similar context where a company hired security guards and supplied them to work guarding other businesses’ sites. Thus, the Appellate Division appeared to implicitly rule that, should this disclaimer be enforceable, the plaintiff would be giving up his right under the Act to pursue a claim against Schering-Plough as a joint employer.

For these reasons, the court found the disclaimer to be unenforceable. It is apparent that the Court’s ruling was intended to protect the injured employee’s interests. Interestingly, although this decision is primarily grounded in workers’ compensation doctrine, it actually provides a civil remedy that would have been not been available to the employee, should the disclaimer have been deemed valid.

Appellate Division Allows Comp Retaliation Case To Proceed To Jury

Workers’ compensation retaliation claims are rare birds in New Jersey, and the case of Robinson v. Armadillo Automation, Inc. explains the standard for proving such cases.  Spencer Robinson worked as a valve technician from May 2005 until August 2011.  He alleged that when he was hired, he disclosed a prior low back condition, and he requested a stool to work while seated, a request which he said the company obliged.  The defendant disputed almost everything Robinson asserted, including that Robinson disclosed a prior condition.  The company asserted that in March 2011 it noticed Robinson was having problems standing and gave him a stool to use but not in 2005.

On April 29, 2011, Robinson felt pain in his neck while assembling a valve.  He said he reported the injury to the company vice president.  Robinson alleged that the VP refused to consider this an injury and would not take him to a doctor. So Robinson got treatment from two doctors on his own and presented a full release from his doctor effective May 12, 2011. Company records did show that the work injury was reported to the carrier.

Defendants denied ever refusing to take him to the hospital, saying the company approved plaintiff’s seeing the family doctor.  The company also maintained that when Robinson returned to work in June 2011, he was having great difficulty standing and working on incoming valve orders.  The President of the company asked Robinson to get an evaluation with his primary care doctor as to his fitness for duty.  The company claimed that Robinson never produced the family doctor clearance note.   The company also claimed that plaintiff’s production was dropping sharply.

For his part Robinson said that the company threatened for the first time to take away his stool when plaintiff tried to return to work after his work incident.    Plaintiff also argued that after his work injury, the company president and vice president complimented him on how hard-working he was.  He further averred that the company president and vice president spoke with him about retirement possibilities for the first time after his injury.  Plaintiff further claimed that he got a note from the family doctor which the company refused to honor because they wanted to speak with the doctor.  Robinson said he then signed a release permitting the company to speak directly to the family doctor, but that never happened. One fact that does not appear to be disputed in this case is that Robinson had not been written up during his employment until he failed to clock out in June 2011.  The company advised plaintiff that his production had fallen off and that the company was observing Robinson’s problems on the job.  The company also maintained that Robinson failed to clock out at lunch time six times.  For his part, Robinson said that the clock out rule was not strictly maintained and the clock was not even working well.  He admitted to not clocking out at lunch only one time.

Although virtually every statement in this case was disputed, one thing not in dispute was that the company did not give Robinson a raise on his anniversary date of May 28, 2011; he was suspended for five days on August 1, 2011; and then fired for declining productivity, failing to punch out at lunch, and failure to get a medical clearance note.

Robinson sued alleging that he was retaliated against due to filing a workers’ compensation claim.   The trial court granted the employer summary judgment but the Appellate Division reversed.  The Court adopted the McDonnell Douglas rule in a retaliation law suit requiring plaintiff to prove 1) membership in a protected class; 2) actual performance prior to termination; 3) termination from employment; and 4) the employer’s pursuit of someone to perform the same work after his termination. On the last point, plaintiff alleged that the company hired two people after he was terminated.

The employer gave non-discriminatory reasons for terminating Robinson, including poor performance, lack of productivity, failure to clock out and failure to get medical clearance.  Robinson in turn argued that these were all pretextual.  He argued that his production never dropped after he returned to work even though the company tried to take away his stool.  He pointed out that he had never been disciplined until after he filed the workers’ compensation claim.  He claimed he had gotten a note from his family physician and had not repeatedly failed to clock out at lunch.  His contention was that the company simply retaliated against him for filing a workers’ compensation claim.

Given the dispute in facts, the Court held that plaintiff had offered sufficient proofs to get to a jury.  “If plaintiff’s proofs are believed at trial, reasonable jurors can readily disbelieve defendants’ stated reasons for the adverse employment actions.” The case shows how problematic retaliation cases can be where the employer has no documentation or record of discipline before the work injury.  Further, the company could have easily gotten its own fitness-for-duty examination in this case rather than debate whether the family doctor would approve plaintiff’s return to work.  This was a small company with 30 employees and perhaps that explains why so little of what took place was documented in memoranda or letters, but clearly the absence of any documentation hurt the employer.

This case can be found at Robinson v. Armadillo Automation, Inc., A05927-13T3 (App. Div. July 20, 2016).

 

 

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