The Supreme Court Takes Up a Redevelopment Law Case and a Child Sexual Abuse Act Case

The Supreme Court announced that it has granted review in two new cases. One of them involved a grant of leave to appeal, while the other is before the Court on a grant of certification.

The leave to appeal case is W.S. v. Hildreth. The question presented, as phrased by the Supreme Court Clerk’s office, is “Was plaintiff’s complaint, which asserted claims under the Child Sexual Abuse Act (CSAA) and the common law, timely filed under L. 2019, c. 120 and L. 2019, c. 239, which amended the CSAA, the Tort Claims Act, and added new statutes of limitations for claims involving sexual abuse?” In a published opinion that does not yet have an official reporter citation, summarized here, a three-judge Appellate Division panel held that the complaint was timely. That ruling affirmed a decision of the Law Division, though on different grounds.

The other new appeal, Malanga v. Township of West Orange, presents this question: “Was the Township of West Orange’s designation of the West Orange Public Library as an area in need of redevelopment under the Local Redevelopment and Housing Law, N.J.S.A. 40A:12A-5(d), supported by substantial credible evidence in the record, and does the public bidding law, N.J.S.A. 40A:12-13, apply?” A two-judge panel of the Appellate Division, in an unpublished opinion, affirmed a ruling of the Law Division that dismissed plaintiff’s complaint. Plaintiff had challenged the area in need of redevelopment designation as not supported by substantial evidence. Both the Law Division and the Appellate Division rejected that position.