Rippon v. Smigel, ___ N.J. Super. ___ (App. Div. 2017).  This opinion by Judge Haas today reverses a dismissal that was based on lack of personal jurisdiction, forum non conveniens, and res judicata.  The main reason was the state of the motion record, which Judge Haas labeled as “sparse,” “thin,” and “meager.”  The lesson of this decision is that discovery is generally required in order to make an adequate record on which a court can decide a motion to di

Acevedo v. Flightsafety International, Inc., ___ N.J. Super. ___ (App. Div. 2017).  In this opinion by Judge Reisner, the Appellate Division held that it was error for the Law Division to offset a back pay award under the New Jersey Law Against Discrimination, N.J.S.A. 10:5-12 to -49 (“LAD”) with a portion of the unemployment benefits that plaintiff received after having been fired for a disability.  The panel ruled that the collateral source statute, N.J

175 Executive House, LLC v. Miles, ___ N.J. Super. ___ (App. Div. 2017).  A tenant who receives a rent subsidy under the federal “Section 8” voucher program, 42 U.S.C. §1437 to 1437z-9, cannot be evicted for non-payment of amounts not defined as rent, or for amounts that are “additional rent,” if the tenant is current with his or her share of the rent payments.  That was the holding of Sudersan v. Royal, 386 N.J. Super. 246 (App. Div. 2005).