Bryant v. County of Cumberland, ___ N.J. Super. ___ (App. Div. 2022). In what may be the shortest published opinion of the current Term, Judge Fisher today addressed this “matter of first impression”: whether “service of a Tort Claims Act notice of claim on a county is sufficient when sent to the county clerk rather than the board of county commissioners.” The Law Division found the notice insufficient, but the Appellate Division reversed that ruling. Judge Fisher observed that “N.J.S.A. 59:8-7 is specific about how to serve the State, calling for its submission...

Devers v. Devers, ___ N.J. Super. ___ (App. Div. 2022). This was a matrimonial appeal. The issue centered around whether a particular financial account (“the Gauss account”) was marital property. Plaintiff wife filed a motion for summary judgment declaring that the account was marital property. The Family Part denied that motion “without prejudice, as [that c]ourt lack[ed] subject matter jurisdiction” on January 16, 2020, and the parties proceeded to litigate other issues. Plaintiff later moved for reconsideration, but the Family Part ruled, in an order entered on...

Last week was a hectic week. So much so that two particularly significant Appellate Division opinions did not get covered here. Belatedly, here are summaries of those two opinions (shamelessly borrowed verbatim from the well-written opinions themselves). State v. O’Donnell, ___ N.J. Super. ___ (App. Div. 2022). Judge Fisher’s opinion in this case concisely summarized the issue and the court’s ruling in the first two paragraphs of the decision: “N.J.S.A. 2C:27-2 imposes criminal liability on ‘person[s]’ who offer or accept from another ‘[a]ny benefit...