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Notable Win: Third Circuit Affirms Summary Judgment Victory on Fourth Amendment Claims Against Local Police Department

Client: Township of Hamilton and several police officers

Court: US Court of Appeals, Third Circuit

Brief Attorney: Charles Holmgren, Esq.

**Results may vary depending on your particular facts and legal circumstances**

Matter Caption: Saintil v. Borough of Carteret, et al.

In the course of an investigation into a homicide and after obtaining a search warrant from a local magistrate, outside law enforcement contacted the Hamilton Police Department for assistance in detaining Ronald Saintil, a person of interest in their investigation. Outside law enforcement had advised the Hamilton PD of the search warrant and that Saintil had refused to answer his door or phone and had attempted to flee his home. The Hamilton PD activated their SWAT Team who breached Saintil’s door, and quickly detained him. After being cleared in the homicide investigation, Saintil filed suit in the District of New Jersey against various law enforcement defendants,  including Hamilton Township and 16 Hamilton police officers, alleging a violation of his Fourth Amendment rights against an illegal search and seizure and the excessive use of force.

Following a successful summary judgment dismissal in the lower court and Saintil’s appeal, the U.S. Court of Appeals for the Third Circuit affirmed the Hamilton Defendants’ dismissal. The Court found that the Hamilton Defendants’ reliance on an apparently valid search warrant was reasonable to support their legal search and seizure and, considering the totality of the circumstances (including the fact that it was in the course of a murder investigation, the possibility that Saintil was armed and dangerous, and they understood there was a valid search warrant), the Hamilton Defendants’ use of the SWAT Team to detain Saintil was an objectively reasonable use of force.

Public Entities Are Not Immune From Frivolous Sanction Litigation

In Borough of Englewood Cliffs v. Trautner, 2024 N.J. Super. LEXIS 37 (App. Div. Apr. 22, 2024), in a published decision, the Appellate Division settled the issue of whether a public entity is immune from sanctions for filing a frivolous lawsuit in accordance with the Frivolous Litigation Statute N.J.S.A. 2A:15-59.1 (hereinafter FLS). The issue stemmed from the Borough’s retention of Thomas J. Trautner and Chiesa Shahinian & Giantomasi, PC (hereinafter CSG), Albert Wunsch III,  Jeffrey Surenian and Jeffrey Surenian and Associates, LLC (hereinafter Surenian) to represent it in affordable housing litigation.

The affordable housing matter was eventually settled but after change of political control in the Borough’s Council, the newly constituted Council sued CSG, Wunsch, and Surenian alleging professional malpractice, breach of contract, unjust enrichment, civil conspiracy, and aiding and abetting in course of their representation of the Borough in the litigation.  Shortly after being served the complaint, each defendant sent the Borough’s attorneys notices demanding the lawsuit be voluntarily dismissed because it was frivolous. Later, the trial court granted defendants’ motion to dismiss the Borough’s complaint with prejudice.

The defendants then filed a motion to recover attorney’s fees on the ground that the Borough failed to withdraw the lawsuit as they demanded. The trial court awarded fees to the defendant attorneys, and one of the basis for this appeal was the Borough’s contention that as a municipality it was immune from frivolous litigation sanctions.

The Appellate Division observed that the issue of whether a State, its agencies and political subdivisions are immune from frivolous litigation sanctions under the FLS statute is an unsettled law with only two prior divergent rulings that address the issue. The Court considered the ruling in In the Matter of K.L.F., 275 N.J. Super. 507, 511 (Ch. Div. 1993), where the Chancery court had concluded that the “ the State and its agencies and political subdivisions do indeed fall within the purview and operation” of FLS. In reaching this conclusion, the court had noted that the legislative intent underlying the statute was to reimburse the party that was victimized by frivolous litigation and, because the legislature did not carve out an exception immunizing state agencies within the language of the statute, it is evident that the legislative intent was not to exempt the state and its agencies from the sanctions.

The Appellate also discussed a different conclusion reached by another Chancery court in Division of Youth & Family Services v. P.M.,  301 N.J. Super. 80, 82 (Ch. Div. 1997). In this case, the court had concluded that a state agency was immune from FLS sanctions focusing on the language of the statute, “A party who prevails in a civil action . . . against any other party may be awarded all reasonable litigation costs and reasonable attorney fees or defense  . . . if the [claim] of the nonprevailing person was frivolous” and holding that the word person does not include the State of New Jersey unless used to designate the owner of property.

The Appellate Division agreed with the reasoning of the Chancery court in K.L.F., holding that a public entity is not immune from sanctions that can be imposed under the FLS. The Court noted that, given the plain language in the statute and the unqualified use of the term, “party,” leads it to conclude that the term does not exclude a public entity “party.” The Court also observed that the legislative objective in enacting the statute was punitive in nature and there is no indication in the statute’s legislative history that public entities were meant to be exempt from sanctions if they filed claims determined to be frivolous. The Court noted that even in subsequent amendments to the statute, after the decision in P.M., the Legislature did not amend the statute to clarify whether public entities were immune. Therefore, based on the plain language of the statute, backed by legislative history, the Appellate Division concluded that FLS allows for sanctions against public entities and affirmed the decision of the trial court.

Minor’s Parent’s Portee Claim Against Public Entity Tolled For The Duration Of The Minor’s Tolling Period

On November 15, 2019, plaintiff Angela Tennant and her minor son, Micah Dunmore, were attending a high school football game when an individual fired a gun into the stands, striking and injuring Micah.  Angela was a witness to the events and, tragically, Micah died from his injuries five days later.  Ninety-one days after the shooting and eighty-six days after Micah’s death, his Estate, his mother Angela and other family members sent a notice of tort claims to the defendant Board of Education, asserting wrongful death and survivor claims.  Additionally, the minor’s mother, Angela, asserted a claim for negligent infliction of emotional distress under Portee v. Jaffee for her injuries allegedly suffered in witnessing the shooting of her son.  The issue in the published Appellate Division Estate of Dunmore case (2022 N.J. Super. LEXIS 7 (App. Div. Jan. 20, 2022)) was whether the tort claims notices were timely filed.

This matter arose, as a result of the Estate filing a motion seeking a declaratory judgment that the tort claims notice was timely filed.  The Board conceded that the wrongful death claims did not accrue until Micah died on November 20, 2019.  Thus, the tort claims notice filed by the Estate and the family members as beneficiaries of the Estate was timely filed.

However, the issue was whether the tort claims notice for Angela’s emotional distress claim under Portee was timely filed.  At the trial court level, the judge deemed Angela’s claim timely filed, indicating that the tort claims notice of February 14, 2020 was filed within ninety days or within three months of the date of the accrual of the cause of action.  The Board appealed that decision, pointing out that Angela’s tort claim was filed actually ninety-one days after the shooting.

The Appellate Division found that the tort claims notice was timely filed, but for different reasons than expressed by the trial court.  First, the Appellate Division noted that the 90 day deadline to file a tort claims act notice under N.J.S.A. 59:8-8 is not equivalent to three months.  The ninety day deadline is specific under the statute and “[t]here is no doubt that when the Legislature said ninety days it meant ninety days and not three months.”

Angela’s Portee claim accrued on the day of the shooting.  Hence, the Board argued that filing her tort claims notice ninety-one days after the shooting meant it was filed late.

In response, Angela argued that because Micah’s time to file a notice of tort claim and complaint was tolled under N.J.S.A. 59:8-8, the time to file her Portee claim should also be tolled for the same period of time.  She relied on the tolling period accorded to a parent’s claim under the statute of limitations provision in N.J.S.A. 2A:14-2.1.

The Appellate Division noted that the time to file a negligence action is governed by the two year statute of limitations set forth in N.J.S.A. 2A:14-2.  However, N.J.S.A. 2A:14-2.1 permits an exception for a parent filing a claim for damages suffered by him because of an injury to a minor child.  In such a situation, the statute extends the time period of a parent to file a claim to the same period of time as provided by law in the case of a minor child so injured. This statutory provision preserves the parent’s claim until the child brings their claim.

Here, the wrongful death claims of the minor did not accrue until Micah died on November 20, 2019.  Thus, his Estate had ninety days from November 20, 2019 to file a tort claims notice and two years from that same date to file a lawsuit.

Thus, under the statute of limitations provision in N.J.S.A. 2A:14-2.1, the time for Angela to file her own lawsuit for her individual claims of emotional distress (under Portee) was also tolled until the Estate instituted suit.

The Court noted, however, that N.J.S.A. 59:8-8 was silent as to whether Angela’s ninety day deadline to file a tort claims notice for her Portee claim, arising from her witnessing of the shooting and injury to Micah, was also tolled.

Under prior case law, it had been established that the “savings provision” under N.J.S.A. 59:8-8 tolls the requirement for a minor to file a tort claims notice until ninety days after the minor’s 18th birthday.  The Appellate Division noted that there was no precedent squarely on point stating N.J.S.A. 59:8-8 also permits the tolling of a parent’s Portee claim.

The Court found that if a parent’s Portee claim arising out of their child’s injury was not also tolled, “it would result in the absurd situation that the parent’s cause of action would likely be brought before a judge and a jury for trial, perhaps years or decades before the child’s lawsuit was initiated.”  The Appellate Division noted that this result would run “contrary to the principles underlying the entire controversy doctrine and promoting judicial economy.”

Thus, the Appellate Division found that the time to file a notice of tort claim must also be consistent concerning a parent and a child.  The Court held that if a minor’s time to file a notice is tolled under N.J.S.A. 59:8-8 and a parent’s time to file a lawsuit regarding their claims is tolled as long as the child’s claim is tolled, “then the time for a parent to file a tort claims notice must also be tolled.”  In considering the two pertinent statutes, the Appellate Division concluded that “the tolling of a notice of tort claim must also be extended for a parent’s Portee claim to promote uniformity and predictability.”

Finally, the Appellate Division noted that Micah’s time to file a notice of tort claim was tolled until he died on November 20, 2019.  Thus, his mother Angela’s emotional distress Portee claim was also tolled until that date.  She filed a notice of tort claim eighty-six days later, which meant that her notice was timely filed under N.J.S.A. 59:8-8 and, hence, she would be permitted to pursue her claim.

Plaintiff’s Failure To Serve Public Entity At Correct Place Of Business With Timely Notice Of Tort Claim Bars Plaintiff’s Personal Injury Claim

The plaintiff Lyndsey Patton was walking in or near the intersection of Union Avenue and West Side Avenue in Jersey City when she was struck by a vehicle owned by defendant Jersey City Municipal Utilities Authority (“JCMUA”).  The accident occurred on June 30, 2019.  On or about September 10, 2019, the plaintiff’s attorney sent a notice of tort claim addressed to JCMUA, but sent it to City Hall on Grove Street instead of JCMUA’s place of business on Route 440 in Jersey City.  Plaintiff later successfully obtained leave from the trial court to file a late notice of claim on JMCUA, which determination was appealed.  The issue on appeal in Patton v. Wiley, 2021 N.J. Super. Unpub. LEXIS 1400 (App. Div. July 7, 2021) was whether the plaintiff had demonstrated the “extraordinary circumstances” under the Tort Claims Act to allow a late filing of a notice of claim.

Pursuant to N.J.S.A. 59:8-8, a party pursuing a cause of action against a public entity under the Tort Claims Act must file a notice of claim within ninety days of accrual of the claim or else be forever barred from recovering from the public entity.  However, a court may exercise the discretion permitted by N.J.S.A. 59:8-9 to allow a late filing “provided that the public entity or a public employee has not been substantially prejudiced” by the delay and also provided that the plaintiff presents “sufficient reasons constituting extraordinary circumstances” for the failure to comply with this statutory requirement.

The question faced by the Appellate Division was whether the plaintiff had met the extraordinary circumstances standard to justify the late filing of the notice of tort claim.  There was no question that plaintiff failed to file a notice of tort claim on JCMUA within the ninety days.  The plaintiff delivered a notice of claim within the required time but to the wrong address.

The Appellate Division noted that there was no mystery as early as the date of the accident that the vehicle was owned by JCMUA and driven by one of its employees and also there was no mystery about the location of JCMUA’s place of business which was included in the police report and was also otherwise readily available through a simple internet search.  The Court held that the plaintiff’s failure to serve the notice of claim on JCMUA at the right location “was a product of attorney neglect or inadvertence” which did not meet the extraordinary circumstances threshold as required by the statute to allow the filing of a late notice of tort claim.

The plaintiff argued that there was little doubt that JCMUA was aware of the event because, in early September 2019, within ninety days of the action’s accrual, plaintiff’s counsel communicated with Qual-Lynx, the administrator who adjusts claims made against JCMUA. The plaintiff’s counsel also advised and served Qual-Lynx with a claim for no fault benefits because plaintiff did not own an automobile and was not otherwise covered by auto insurance.

The Court noted that this submission to Qual-Lynx, however, made no mention of a personal injury claim to be asserted against JCMUA or its employee, and “it cannot seriously be argued that a notice or communications with a public entity’s adjuster or insurer about a related claim constitutes the notice required by N.J.S.A. 59:8-8.”  (emphasis added). Moreover, the Appellate Division noted that the Qual-Lynx representative certified in the opposition to plaintiff’s motion for leave to file a late notice of claim “that he told plaintiff’s attorney during their September 6, 2019 telephone call that plaintiff needed to serve a notice of tort claim directly on JCMUA.”  As of that date, there was still time left to serve a notice of tort claim on JCUMA within the ninety day time period.

While plaintiff thereafter did forward a notice of tort claim, it was sent to City Hall, not JCMUA’s place of business on Route 440.  The Appellate Division noted that this was not a situation where the claimant or her representatives might have been confused about the identity of the public entity that caused the injury.  She knew at the scene of the accident that the driver worked for the JCMUA and, further, in corresponding with Qual-Lynx within the ninety day time period, the plaintiff’s then attorney referred to Qual-Lynx’s insured as “Jersey City MUA.”

The Appellate Division noted that JCMUA was “aware of and had already conducted an investigation into the accident but, in light of the absence of a timely notice of claim, JCMUA had no reason to know plaintiff intended to make a personal injury claim against it.”  Based upon these facts and circumstances, the Court found that the plaintiff’s failure to serve the notice of tort claim was the product of attorney inadvertence.  Counsel was or should have been aware of the identity of the public entity that was involved in the accident, as well as the correct address for the JCMUA.

Finally, the Appellate Division found that “[w]hile it may be viewed as a displeasing result because it seems JCMUA was aware of the accident and aware Qual-Lynx had been in communication with plaintiff about her no fault benefits claim, there is no question the Legislature intended – when it amended N.J.S.A. 59:8-9 – to require a showing of ‘extraordinary circumstances’ to set a high bar for relief.”

The Appellate Division noted that the Supreme Court had clearly established that attorney negligence or inadvertence did not constitute “extraordinary” within the meaning of N.J.S.A. 59:8-9.  Hence, the Court found that it was “constrained” to conclude the judge mistakenly exercised his discretion in allowing plaintiff to file a late notice of tort claim.  Accordingly, the Appellate Division reversed the trial court’s ruling in permitting the late notice of tort claim to be filed against the JCMUA.  Thus, the end result was that the claim against the JCMUA for this accident was barred.

 

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 30 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.

Plaintiff Quadriplegic Found To Have Sufficient Basis To Justify Filing Of Late Notice Of Tort Claim Against Public Entity

On April 9, 2017, plaintiff Jonathan Jeffrey was involved in a one vehicle motorcycle accident, resulting in complete quadriplegia.  Approximately six months after the accident, he consulted counsel, at which point, he learned that his injuries may have been caused or significantly aggravated by the emergency medical technicians who placed him in the ambulance.  In the published decision of Jeffrey v. State, 2021 N.J. Super. LEXIS 65 (App. Div. May 18, 2021), the plaintiff appealed an order of the Law Division denying his motion for leave to file a late notice of tort claim.

Plaintiff’s injuries resulted in several surgeries, including spinal decompression and fusion surgery. He suffered a complete spinal cord transection at the C6-C7 level of his spinal cord, resulting in complete quadriplegia.

Plaintiff was released from the hospital on April 17, 2017 and transferred to a rehabilitation center for two months.  He continued to receive rehabilitation therapy on an out-patient basis for approximately four more months.

However, plaintiff remained completely disabled and unable to perform rudimentary movements, let alone to work.  He had an inability to voluntarily move the upper and lower parts of his body.

Plaintiff retained counsel on November 15, 2017.  At that time, plaintiff was using a wheelchair for mobility and had minimum movement of his upper body.  His decision to consult counsel was, in large part, due to a collection notice dated October 24, 2017 from the hospital.

Plaintiff filed a certification that the first time that he understood that he had a potential claim against the emergency medical services and/or other persons that provided medical care to him immediately after the April 2017 motorcycle accident was when he consulted counsel.  Thereafter, on March 20, 2018, his counsel filed a motion for leave to file a late tort claims act notice.  The lawyer certified that it was not until September 28, 2017 that she finally received sufficient information from a representative of the hospital to conclude that plaintiff’s permanent disabilities may have been caused by some or all of the medical care and treatment he received at the scene of the accident.  She sent in Tort Claims Act notices to the relevant public entities and thereafter filed a motion to seek leave to file a late notice of tort claim.

Pursuant to the Tort Claims Act, a plaintiff must file a notice of claim within ninety (90) days of its accrual (N.J.S.A. 59:8-8).  The Law Division judge has the discretion to grant a claimant leave to file a notice of claim beyond that ninety (90) day time frame, if he or she provides by Affidavit:

(1)        Extraordinary circumstances for his or her failure to file a timely notice of claim; and

(2)        The public entity or employees involved have not been substantially prejudiced by the plaintiff’s tardiness.

The plaintiff argued to the trial court judge that the gravity of his injuries made it “impossible or impractical to view this delay as a failure to exercise due diligence.”  The defendant argued that the motion judge properly exercised his discretion to find plaintiff did not show extraordinary circumstances to justify relief.

The Appellate Division concluded that the trial court judge mistakenly exercised his discretionary authority and reversed.  The Court found that the motion judge “failed to duly appreciate the magnitude of plaintiff’s injuries and their life-altering ramifications.”

In the appeal, the plaintiff argued that the Law Division made a mistake in finding that the accrual date was April 9, 2017, the actual date of his accident.  The trial court judge justified his decision in finding that, while it was difficult for the plaintiff to function in his daily life, there was insufficient evidence in the records to show that the plaintiff was not able to file a timely claim due to the severity of his injuries and his medical care.  The court had noted that the plaintiff was released for treatment by in-patient rehab and that there was nothing to indicate that plaintiff through a family member, friend or individual, was prevented from contacting or retaining legal counsel.

The Appellate Division found that the trial court judge “grossly misapprehended the magnitude of plaintiff’s injuries.  Plaintiff was 25 years old at the time of the accident.  In one catastrophic event, he lost complete movement and sensation of his body.”

The Court further pointed out that after completing two months of in-patient rehabilitation, it would “be beyond insensitive to impose a duty on plaintiff to seek legal advice through surrogates composed of family members or friends, during this life-altering adjustment period.”  The Appellate Division concluded that: “we are certain the Legislature did not intend for the judiciary to construe the term ‘accrual’ in N.J.S.A. 59:8-8 in a manner that abandons all vestiges of basic human empathy.”

Accordingly, the Appellate Division held that November 15, 2017 was the accrual date for his claim.  Thus, plaintiff’s motion to seek leave of the court to accept the TCA notice of claim was only thirty-five (35) days beyond the ninety (90) day statutory requirement.

The Appellate Division noted that after plaintiff completed his two month in-patient rehabilitation program, plaintiff was then required to confront and adjust to his physical limitations.  Further, the Court noted that plaintiff’s inherent difficulties associated with shifting from a motorcyclist to a quadriplegic wheelchair user “cannot be viewed as a barrier to deny plaintiff access to our civil courts.”

Thus, the Appellate Division found that the facts were sufficient to constitute “extraordinary circumstances” pursuant to N.J.S.A. 59:8-9 which permits the filing of a late notice of tort claim.  Accordingly, the Appellate Division reversed the trial court’s denial of the plaintiff’s request to file a late notice of tort claims against the public entities that the plaintiff believed may have exacerbated his injuries.

 

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 30 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.

Don’t Let Your Public Entity Client Get Tripped up by a Pothole

By way of background, a public entity is only liable for an injury proximately caused by a condition of its property within the limitations of N.J.S.A. 59:4-2.  To impose liability on a public entity pursuant N.J.S.A. 59:4-2, a Plaintiff must prove the following five elements: (1) a dangerous condition existed at the time of Plaintiff’s injury; (2) Plaintiff’s injuries were proximately caused by the dangerous condition; (3) the dangerous condition created a reasonably foreseeable risk of the kinds of injuries that Plaintiff sustained; (4) the public entity created the dangerous condition or had notice of it a sufficient time prior to Plaintiff’s injury to have taken measures to protect against it; and (5) the public entity’s failure to take action to protect against the dangerous condition was palpably unreasonable.  Failure to prove all five elements defeats Plaintiff’s claim.

In order to satisfy the first element, a claimant must show that there was a dangerous condition, defined as a “condition of property that creates a substantial risk of injury” when the property is used with due care in a reasonably foreseeable manner.  N.J.S.A. 59:4-1a.  Courts interpreting this definition ask whether the condition created a substantial risk of harm to persons, generally, who would use the public property with due care in a foreseeable manner.

In a long line of cases, courts have held that minor imperfections on public travel-ways are not dangerous conditions under the Tort Claims Act because they do not pose a substantial risk of injury to the public.  Courts have so held notwithstanding the fact that the imperfections may directly cause Plaintiffs severe injuries or even death.

For example, in Polyard v. Terry, 160 N.J. Super. 497, 504, 507-08 (App. Div. 1978), aff’d o.b. 79 N.J. 547 (1979), a man drove his car over a three-eighths-inch declivity connecting a highway to a bridge, and then drove over a section of pavement that had comparatively less traction than the rest of the road.  As he drove over these two defective conditions, another car cut him off.  The man lost control of his vehicle, ultimately injuring one plaintiff and killing another.  In a subsequent lawsuit against the State, the Plaintiffs’ theory of the case — backed up by expert testimony at trial — was that the defective conditions of the road contributed to the man’s losing control of his car.  The jury agreed, and found the State thirty percent liable for causing the accident.  The Appellate Division (and the Supreme Court, which adopted the Appellate Division’s reasoning in its entirety) concluded that there was no dangerous condition within the Tort Claims Act notwithstanding that the jury reached a contrary conclusion, and notwithstanding that two defects in the road caused the Plaintiffs’ injury and death.  The Court explained that the Tort Claim Act establishes a threshold level of objective severity to make a defect actionable — defects falling below that threshold are not actionable as a matter of law.  The Court additionally held that a baseline number of defects must be tolerated in public property as being consistent with public expectations.

Another case rejecting the dangerousness of a condition that caused severe injuries is Charney v. City of Wildwood, 732 F. Supp. 2d 448, 452-53 (D.N.J. 2010).  There, a woman, while walking on the Wildwood boardwalk, tripped over a hole that was roughly shaped like a right triangle measuring approximately three and three-eighths inches long and one and one-half inch deep.  Even though the woman sustained multiple fractures, and even though there was evidence that the defendant had repaired adjacent wooden boards as well as the subject board in the past, the Court held that there was no dangerous condition as a matter of law.

Yet another example is Cordy v. Sherwin Williams Co., 975 F. Supp. 639, 641, 643 (D.N.J. 1997) where a bicyclist sustained paralysis when his bicycle struck the property owner’s elevated railroad tracks, thereby launching him head-first over the handlebars and on to the street pavement.  The railroad track was raised between 5/8 and 7/8 of an inch above the roadway.  The court granted summary judgment finding that so slight a differential could not possibly be a dangerous condition creating a substantial risk of injury.  The court found that, that would impose an unfair onerous burden on the County to keep roadways free of even the slightest imperfections.  The court found further that even if one assumed that the small differential was a dangerous condition allowing such a difference could not possibly be found to be palpably unreasonable.

These three cases represent but a few of the many that hold that minor imperfections in public travel-ways are not actionable under the Tort Claims Act even if they do happen to cause substantial injuries.

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