State of New Jersey in the Interest of N.P., ___ N.J. Super. ___ (App. Div. 2018).  This decision by Judge Messano addresses four appeals involving seven different juveniles. The broad issue presented was “whether a juvenile complaint charging a crime or repetitive disorderly persons offense may be diverted without the prosecutor’s consent.”  Judge Messano carefully analyzed the applicable statutory and court rule sources of relevant law, and concl

Baez v. Paulo, ___ N.J. Super. ___ (App. Div. 2018).  This was a medical malpractice/wrongful death case.  The Law Division had precluded plaintiff from adding three doctors as defendants after the statute of limitations had expired, ruling that plaintiff had not exercised sufficient diligence to identify those defendants, who had been named as fictitious defendants under Rule 4:26-4, in timely fashion.  Despite having found that the statute of limitations had run out as to the three doctors, t

Last week, the Supreme Court announced that it had granted certification in five more cases.  Three of them are criminal appeals, one involves additur after a jury verdict, and one implicates the entire controversy doctrine.

The question presented in State v. Santamaria, as phrased by the Supreme Court Clerk’s Office, is “Did the State’s introduction of more than fifty sexually explicit photographs, which were taken after the victim turned eighteen, for the purpose of establishing the existence of a sexual relationship between defendant and the victim when the