F.K. v. Integrity House, Inc., ___ N.J. Super. ___ (App. Div. 2019). This charitable immunity case centered on how much in charitable contributions (as opposed to, say, government support) defendant received. In order to satisfy the three-pronged test for charitable immunity, the second prong of which (the only one at issue on this appeal) requires that an entity be “organized exclusively for religious, charitable or educational purposes,” it was necessary for defendant, a drug treatment facility, to show a charitable purpose. To do that, the percentage of its funds that came...

S.L.W. v. New Jersey Div. of Pensions & Benefits, ___ N.J. ___ (2019). The statute governing the police and firemen’s retirement system (“PFRS”) makes children and widowed spouses of police and firefighters who die after retirement eligible to receive survivor benefits. In this case, an adult woman with disabilities, S.L.W., sought to obtain such benefits after her father, a career law enforcement officer, died in retirement. The issue in Justice Timpone’s decision in this case today was whether S.L.W. qualified as a “child” under the statute. The...

The Supreme Court announced late yesterday that it has granted certification in three cases. Two of the matters produced published opinions in the Appellate Division. The first of those is New Jersey Land Title Ass’n v. Rone. The question presented on that appeal, as phrased by the Supreme Court Clerk’s office, is “May a county register or clerk charge a ‘convenience fee’ for the electronic filing of documents concerning real property?” The Appellate Division, in an opinion that was reported at 458 N.J. Super. 123 (App. Div. 2019) and discussed here, held...