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In reading an unpublished Appellate Division decision recently, I learned about the “two-court rule.”  That rule, which dates back at least as far as a 1949 Supreme Court of the United States decision, Graver Tank & Mfg. Co. v. Linde Air Products Co., 336 U.S. 271 (1949), states that an appellate court will not “undertake to review concurrent findings of fact by two courts below in the absence of a very obvious and exceptional showing of error.” The two-court rule apparently first came to New Jersey in Midler v. Heinowitz, 10 N.J. 123 (1952).  Our Supreme Court...