Should Intentional Infliction of Emotional Distress Cases Be Treated Differently Depending on Whether or Not They Take Place at Work?

Should a claim of intention infliction of emotional distress be treated differently if it occurs in the workplace as opposed to a non-employment situation? This question was answered in Ingraham v. Ortho-McNeill, 422 NJ. Super. 12 (App. Div. 2011)
Plaintiff Cecelia Mavica Ingraham was employed by defendant Ortho-McNeil Pharmaceutical between 1994 and 2006. The plaintiff had one child, Tatiana, who was diagnosed with acute lymphocytic leukemia in 2003. At the time, Tatiana was a junior in high school and a member of several honors societies; a student at the New Jersey School of Ballet; and was planning on attending Cornell University to study biology.  Unfortunately in 2005, Tatiana contracted an infection and passed away.
In remembrance of her daughter, plaintiff kept pictures of her as well as her ballet shoes in her work space.  Although sympathetic, many of her co-workers felt uncomfortable with the frequency of conversations plaintiff initiated involving the death of her daughter.  A year and a half later, a supervisor confronted plaintiff and asked her to stop.
Plaintiff quit and sued, alleging that she suffered emotional distress along with heart palpitations from the abuse.  She filed a three-count complaint alleging a violation of
  1. New Jersey Law Against Discrimination N.J.S.A. 10:5-1 to -49 (“LAD”)
  2. Intentional infliction of emotional distress and
  3. Constructive discharge
The court reasoned that in order for a plaintiff to prove intentional infliction of emotional distress, he or she must prove that
  1. defendant acted intentionally or recklessly;
  2. defendant’s conduct was extreme and outrageous;
  3. defendant’s conduct was the proximate cause of plaintiff’s emotional distress; and
  4. the emotional distress suffered by plaintiff was so severe that no reasonable [person] could be expected to endure it.
Id. at 366-67.
Defendants argued that the plaintiff could not prove the first or second elements as a matter of law. The court agreed, stating:

The law provides no different standard of proof that applies in the workplace from other places where emotional distress might result. The employer-employee relationship is no more special and conductive to emotional distress than, for example, a doctor-patent relationship, or the relationship of a husband and wife in a hostile divorce.

Id. at 1196.
The court also stated that “[i]t is extremely rare to find conduct in the employment context that will rise to the level of outrageousness necessary to provide a basis for recovery for the tort of intentional infliction of emotional distress.”
Id. at 23-24.
The court concluded that the evidence provided by the plaintiff was not sufficient to support a cause of action for intentional infliction of emotional distress. Moreover, it held that intentional infliction of emotional distress cases that arise in the workplace are analyzed the same way as they would in non-employment settings. The conduct must be exceptionally egregious. In this case, it was not.

May Courts Unilaterally Modify the Terms of an Oral Settlement Agreement to Which the Parties Agreed on the Record?

In Highland Capital Corp., v. Donna P. Denier M.D., P.C. et al., No. A-4832-10T4 (N.J. Super.  App. Div. 2013), Donna Denier, M.D. (“Defendant”) entered into a lease with Digirad Corporation (“Lease”) for a piece of equipment named “Cardius 1”. Id. at 2.  Highland Capital Corp., (“Plaintiff”) was the party that financed the Lease. Id.
This dispute arose when Defendant stopped making the agreed upon payments to Plaintiff. Id.  As a result of Defendant’s failure, Plaintiff sued her for breach of contract in the Law Division of the New Jersey Supreme Court (“Lower Court”). Id. Instead of proceeding with litigation, the parties entered into a settlement agreement. Id. at 3. Following discussions among each party’s counsel and the Law Division Judge, the parties orally placed the terms of their settlement on the record (“Settlement”). Id. Some of the main points of the Settlement were as follows:

1.      Defendant is to make monthly payments to Plaintiff in the amount of $2,778.00 plus tax for 36 months; and
2.      If Defendant made all monthly payments, at the end of the 36 months Plaintiff will transfer ownership of Cardius 1 to Defendant.

However, the parties were unable to agree on how best to put the terms of the Settlement in writing. Id. at 5.Unable to come to an agreement, the parties participated in a telephone conference with the Lower Court. Id. at 6. Based upon this conference, Plaintiff submitted a proposed written agreement to the Lower Court for signature. Id.  The Defendant objected, stating that it did not accept the terms of Plaintiff’s proposed written agreement. The Defendant argued that it encompassed different terms than those placed on the record (“Proposed Agreement”). Id. Nonetheless, the Lower Court signed Plaintiff’s Proposed Agreement. This meant that the Plaintiff’s terms of the agreement, which were not agreed to by Defendant, were now enforceable against Defendant. Id.
Defendant appealed to the Appellate Division of the Supreme Court of New Jersey (“Appellate Court”). Id. at 7.  In its appeal, the Defendant argued that the Lower Court did not have the authority to sign the agreement because she never consented to it and it “materially changed the terms of the settlement placed on the record.” Id.
In its analysis the Appellate Court explained that as a matter of public policy, New Jersey courts favor the enforcement of settlement agreements. Id. at 8.  This policy acknowledges the notion that the parties to a dispute are in the best position to determine how to resolve a contested matter in a way that is least disadvantageous to everyone. Id. Thus, courts strain to give effect to the terms of a settlement agreement wherever possible. Id.  Importantly, the Appellate Court noted that a settlement agreement does not have to be in writing to be enforceable “…the fact that an agreement is oral, rather than written, ‘is of no consequence.’” Id.
However, the Appellate Court explained that settlement agreements are contractual in nature. Id. at 9. Thus, no settlement agreement exists unless the parties agree to the essential terms of the agreement and manifest an intention to be bound by those terms. Id.  Appellate Courts do not have the power to modify and/or add to the terms of the settlement agreement. “It is not the court’s function to make a contract for the parties or to supply terms that have not been agreed upon.” Id. at 10.
The Appellate Court explained that the terms of the Proposed Agreement was not an accurate representation of the Settlement the parties agreed to on the record. Id. at 12. For instance, under the Proposed Agreement, the Plaintiff was permitted to retain title to Cardius 1 and all proceeds of sale even if Defendant made all payments to Plaintiff in accordance with the Settlement. Id.  To the contrary, the Settlement indicated that the Defendant would retain ownership of Cardius 1, provided she made all payments to Plaintiff in accordance to its terms. The Appellate Court stated that the Lower Court unilaterally modified the terms of the Settlement. Id. The Lower Court’s improper modification of the Settlement clearly benefited the Plaintiff and harmed the Defendant.  Id.
Accordingly, the Appellate Court reversed the Lower Court’s approval of the Proposed Agreement. Id. at 13. In that regard, the Appellate Court directed the Lower Court to either form an agreement to which both parties agreed or, if the parties are unable to come to an agreement, simply to dismiss the case and enforce the terms of the original oral Settlement.   Id.

Is a Loan Discharged When the Lender Releases the Liens on Collateral Prior to the Payoff Checks Clearing?

In JPMorgan Chase Bank, N.A., v. Jeffco Cinnaminson Corporation, et. al., No. A-2601-10T3
(N.J. Super. Ct. App. Div. March 27, 2012), JP Morgan Chase Bank, N.A.  (“Plaintiff”) sued Jeffco Cinnaminson Corporation (“Jeffco”) and Paul T. Andrews (“Andrews”) (collectively “Defendants”) based upon its premature disbursement of collateral held as security against two loans.

In that case, Plaintiff granted Jeffco two loans in order to acquire a Ford GT and a Ferrari (collectively the “Vehicles”). In regard to both loan agreements (collectively the “Agreements”), Andrews signed the Agreements as a cosigner which made him a
guarantor of the debt. Id. at 4.

Plaintiff disbursed the money and, in order to secure the loans, recorded liens on the Vehicles. Subsequently, Defendants entrusted the vehicles to Alfred Sciubba (“Sciubba”), who owned and operated a specialty car business named “Auto Toy Store.” He agreed to find buyers for the Vehicles.  Id. at 4.

Sciubba found buyers for both vehicles. It provided pay off checks from Jeffco’s bank account to satisfy the car loans so the sale could be consummated (the buyers obviously would not want to purchase the cars with liens still recorded on the title). The problem arose when the Plaintiff bank endorsed the liens as paid before the check cleared. In fact it did this on two separate occasions, since the cars sold at different times. However, since neither check cleared due to insufficient funds in Jeffco’s bank account, Plaintiff was left with two unpaid and unsecured loans in Jeffco’s and Andrews’ names. Id. at 6-7.

As a result, Plaintiff filed suit in the Law Division of the Superior Court of New Jersey  (“Lower
Court”) against Jeffco and Andrews to recover the amounts due. Defendants argued that because Plaintiff had failed to protect the collateral, their two loans were discharged. They also filed a counterclaim which alleged that Plaintiff was negligent because it should not have endorsed both liens as paid before either of the checks had cleared. Id. at 7-8.

Subsequently, Plaintiff filed a motion for summary judgment and Defendants filed a cross motion for summary judgment. A motion for summary judgment allows a Court to determine a case without resort to a trial when there are no material issues of fact and judgment can be granted by applying
the relevant law.

Defendants’ submitted to the Court an expert report and opinion. The expert opined that Plaintiff’s release of the liens violated financial industry standards and was contrary to its policies and procedures. Further, the expert asserted that it failed to properly monitor and manage the Jeffco
loan portfolio after the first payoff check (for the Ford GT) bounced. Id. at 8-9.

The Lower Court stated that Plaintiff “implicitly knew” Sciubba was in the business of selling cars because it received a check from “Auto Toy Store.” It reasoned that because Sciubba regularly sold cars to the public, that alone was a sufficient basis for the Plaintiff to reasonably believe that the checks received from him were adequate and sufficient. Thus, it asserted that it was proper for Plaintiff to have endorsed the liens as paid before the checks had cleared. Further, the Lower Court stated that Defendants could not complain about Plaintiff’s release of the liens because they had set in motion the very facts that led to the consignment of the vehicle to the dealership.

Accordingly, the Lower Court granted Plaintiff’s motion for summary judgment against Defendants for the amounts due plus approximately $40,000.00 in attorney’s fees. Id.

Subsequently, Defendants appealed to the Superior Court of New Jersey, Appellate Division (the “Appellate Court”). In its analysis, the Appellate Court considered Plaintiff’s argument based upon Chapter Nine of the New Jersey Commercial Code (the “UCC”). It claimed that whenever an “innocent purchaser” is involved in the acquisition of an automobile, the rights of a secured lender, almost instantaneously (and inexorably), must bend to the will of the buyer.  Id. at 11-12. The Court rejected that argument.

It explained that under N.J.S,A. 12A:9-315(a)(1) and (2), a properly filed and recorded lien was not extinguished when the secured property was transferred to another, unless an exception to the UCC applied. One such exception is N.J.S.A. 12A: 9-320(a) because it automatically severs the lien so that the purchaser of the goods enjoys them with clear title; free of any liens due to their seller’s debt. 14. For example, if you purchased a new coat from a department store you will own that coat without any fear that the department store’s creditors have any rights in them. N.J.S.A. 12A: 9-320(a)

Except, as otherwise provided in this subsection (e), a buyer in the ordinary course of business, other than a person buying farm products from a person engaged in farming operations, takes free of a security interest created by the buyer’s seller, even if the security interest is perfected and the buyer knows of its existence.  

(emphasis added) Id.

Further, the Court noted that the UCC did not require a secured lender to blindly release a lien without conducting reasonable due diligence; including ensuring that the proffered payoff is sufficient to extinguish the outstanding amount due on the loan. Id. at 13.

In its analysis, the Court explained several reasons why the Lower Court’s grant of summary judgment in favor of Plaintiff was improper. Some of those reasons were:

  • Contrary to the Lower Court’s conclusion, Plaintiff could not have implicitly known that the
    entity transmitting title to the vehicles was in the business of selling vehicles because it never received a check from the Auto Toy Store. Rather, Plaintiff received a check from Jeffco who was not an entity that was in the business of selling motor vehicles at the time Plaintiff received the checks. Id.
  • The security interests in this case were created by Jeffco and Andrews, not the Auto Toy Store.
    Since, the buyers of the Vehicles were dealing with Auto Toy Store, not Jeffco and Andrews, the provision did not apply to them. Thus, those buyers would have taken free of any security interest created by Auto Toy Store (the buyer’s seller), but not those created by Jeffco and Andrews. Therefore, that argument was immaterial.
    Id. at 15.
  • There was no requirement in the UCC that mandated a speedy release of Plaintiff’s security
    interests in the Vehicles. In light of Defendant’s expert’s opinion, it was possible that had the Plaintiff waited a few more business days, instead of robotically processing the lien releases, its discovery of the checks’ dishonor might have enabled Defendants to prevent the conversion
    of the purchase proceeds. Id.

Since many questions of fact remained open for the trier of fact to determine, the Appellate Court reversed the grant of summary judgment in favor of Plaintiff, vacated the reallocation of attorney’s fees without prejudice, and remanded back to the Lower Court. Id. at 21.

Does the Omission of Drink Prices on a NJ Restaurant’s Menu Violate the NJ Truth in Consumer Contract Warranty and Notice Act?

Does a restaurant menu constitute a notice or sign pursuant to New Jersey’s Truth in Consumer Contract Warranty and Notice Act (“Act”)? If so, would the omission of prices from a menu violate the Act? In Watkins v. DineEquity Inc., 11-7182 (D.N.J. August 28, 2012),  the District Court of New Jersey recently answered the former question in the positive, and the latter question in the negative.

In that case, a class action was brought against DineEquity Inc., Applebees Neighborhood Grill and Bar and International House of Pancakes, LLC (collectively “Defendants”). Defendants offered certain drinks on their menu without listing the prices.   Candice Watkins (“Plaintiff”) alleged in her
complaint that Defendants’ practice of omitting drink prices from their menu violated the Act. Id. at 2.

Plaintiff filed her complaint in the Superior Court of New Jersey, Law Division (“State Court”). Subsequently, Defendants removed the action from the State Court to the United States District Court for the District of New Jersey (“Federal Court”) based on diversity jurisdiction. Plaintiff argued that “offering such beverages for sale without indicating the prices violates New Jersey Law, in the [Act], and is contrary to clearly established New Jersey law requiring point-of-purchase notice of an item’s
selling price.” Id.  at 2.  Defendants filed a Rule 12(b)(6) motion to dismiss the lawsuit for failure to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6); Id.

The Court explained that in order for the case to survive Defendants’ motion to dismiss, Plaintiff needed to establish on its face that Defendant violated the Act. Plaintiff was required to show that the
following four (4) elements were met:

(1) the plaintiff was a consumer within the statute’s definition;

(2) the defendant was a seller, lessor, creditor, lender or bailee;

(3) the defendant (a) offered or entered into a written consumer contract or (b) gave or displayed any written consumer warranty, notice, or sign; and

(4) the offer or written contract, warranty, notice or sign included a provision that violated any clearly established legal right of a consumer or responsibility of a seller

Id. at 6.

Element One

The Court addressed element one minimally. It merely stated that the Act defined “consumer” as “any individual who buys, leases, borrows, or bails any money, property or service which is primarily for personal, family or household purposes.”  N.J. Stat. Ann. § 56:12-15. The Court presumed element one was satisfied and did not proceed further with its analysis. Id. at 6 n.3.

It is possible that it based its determination on the fact that Plaintiff was an individual who purchased drinks for personal consumption rather than resale.

Element Two

The Court did not address element two. However, presumably Plaintiff was able to satisfy it because Defendants were considered “sellers” of food and drink items to the public.

Element Three

The Court held that element three was satisfied. It explained that a menu “fits within the definition of a notice or sign, or both, as presented in the [Act’s] context of a consumer transaction because a restaurant menu is a written document that announces menu items and identifies the specific food and
beverage products offered for sale by the restaurant.” Id. at 15.

Further, the Court considered Black’s Law Dictionary’s definition of “offer” which was, “The act or instance of presenting something for acceptance.” Black’s Law Dictionary 1189 (9th ed. 2009);  Id.
at 10. On this basis, it held that “a restaurant menu may be considered an offer, a notice, and a sign for [Act] purposes.” Id. at 15.

Element Four

Element four was not satisfied. It held the Act applied solely to illegal terms and provisions that are included, in writing, in the statutorily significant documents (i.e. an offer, notice, or a sign). Omitted
language was not sufficient to invoke the Act’s protections. Id. at 19. The Court reasoned that the
phrase in element four, “which includes any provision”, refered to inclusions not omissions. Id. at 16.

The Court highlighted a very interesting distinction between something that is omitted and something that is included. It explained that when something is omitted, that can include a very large range of possible items. However, when something is included, the range of possible items is much more narrow. Therefore, since the statute was limited solely to items that were included on the menu, it would have been an unfair expansion of the intent of the statute to include items that were omitted, as well. The Legislature was “concerned with contracts, warranties, notices and signs that include illegal
provisions intended to ‘deceive[] a consumer into thinking that they are enforceable . . . .’” (in other words, items that were included).  Id. at 14.

Accordingly, the Court found that merely omitting drink prices from a restaurant menu without more did not state a claim under the Act. Id. at 23.  The Court did not find that omissions posed the “same risk of misleading a consumer into failing to enforce her legal rights as an affirmative misrepresentation . . . .” Id. at 22. Thus, it granted Defendants’ Rule 12(b)(6) motion to dismiss the lawsuit. It held that Plaintiff, under these circumstances, failed to make a claim upon which relief could be granted. Fed. R. Civ. P. 12(b)(6). Id. at 23.


© 2013 Nissenbaum Law Group, LLC

May a Plaintiff Amend His Claim After Identifying the Incorrect Defendant?

In a world filled with partnerships, subsidiaries, and joint ownerships, identifying a defendant is not as easy as it sounds. However, if a plaintiff fails to name the correct defendant, he may risk dismissal. The question becomes what does a plaintiff need to do to ensure that his  claim is not dismissed? Is it
reasonable to rely on a party’s representation that they are the defendant?  What will be the result if a
party deceives another into believing they are defendant, when they are not?
In Dashi Slatina & Vjollca Slatina  v. D. Construction Corp. and Armored Inc., A-0851-10T2 (N. J. Super. Ct., App. Div. August 3, 2012), the plaintiff, Dashi Slatina, suffered serious injuries at work. He was erecting a masonry wall when it toppled on him. He filed suit against Newport Associate Development Company (“Newport”) under the belief that Newport was the owner and/or general contractor. However, the trial court dismissed the complaint with prejudice against the plaintiff because Newport was not the actual owner and/or general contractor.
Thereafter, the plaintiff filed a motion to amend the complaint in order to include the actual owner and general contractor. The basis for the motion was that plaintiff had been misled into believing that it had named the correct defendant. For example,
  • Newport initially admitted it owned the property where the plaintiff was injured.
  •  Newport’s interrogatory answers and it’s counsel’s certification did not expressly deny ownership, nor did it identify the actual owner and or general contractor (which Newport was actually linked to by common ownership).
  • The insurance policies that named the actual owner also included Newport as a named insured after the accident occurred.
The trial court denied plaintiff’s motion. In its holding, the court explained “that absent a pre-existing complaint, a plaintiff has nothing to amend”. Therefore, the very idea of amending a complaint that
had just been dismissed was illogical.  In its holding, the trial court mentioned that the only way to restore (and essentially amend) the complaint would be upon reconsideration, or if judgment were vacated after an appeal.
On appeal, the Superior Court considered whether the trial court abused its discretion when it denied the motion for leave to amend. In reversing the trial court’s decision and holding for the plaintiff, the Superior Court explained that although the trial court applied the correct standard for determining reconsideration, it did not construe the standard as liberally as the circumstances warranted. Rule 4:50-1 states,
On motion, with briefs, and upon such terms as are just, the court may relieve a party or the party’s legal representative from a final judgment or order for the following reasons:
(a) mistake, inadvertence, surprise, or excusable neglect;
(b) newly discovered evidence which would probably alter the judgment or order and which by due diligence could not have been discovered in time to move for a new trial under R. 4:49;
(c) fraud (whether heretofore denominated intrinsic or extrinsic), misrepresentation, or other misconduct of an adverse party; (d) the judgment or order is void;
 (e) the judgment or order has been satisfied, released or discharged, or a prior judgment or order upon which it is based has been reversed or otherwise vacated, or it is no longer equitable that the judgment or order should have prospective application; or
 (f) any other reason justifying relief from the operation of the judgment or order.
The Superior Court held that although the circumstances of this case do not fall into subsection (a) through (e) of Rule 4:50 -1, the trial court had the authority to grant plaintiff’s leave to amend under
the catchall, subsection (f). That subsection allowed the trial court to consider whether it was “in the interest of justice” to restore the complaint for the purpose of enabling the plaintiff to add additional parties. Thus the Court explained that under subsection (f), the trial court had sufficient discretion to grant relief to address exceptional circumstances.
The Court found exceptional circumstances to be present in that case because the great injustice it would create if it held otherwise. The Court explained that Newport initially admitted to owning the
property and throughout its interrogatories never expressly stated that they did not. In fact, Newport was not only named as an insured on the post-accident insurance policy, but they also turned out to be a related entity to the “true owners.”
The Court also recognized that the policy was one promoting decisions on the merits. To hold otherwise would result in the“true owners” being able to avoid responding to the merits of the lawsuit. This would be due to the delayed disclosure by Newport, a related entity. The Court also took into consideration the fact that Newport would suffer no prejudice because the complaint would be restored solely for the purpose of allowing the new amendment and would not subject Newport to potential liability. Finally, the Court noted that plaintiff acted promptly to restore the complaint after judgment was entered. All of these factors favored allowing plaintiff to restore it to the active docket.
The lesson of this case is that a party should always thoroughly investigate whether or not it is bringing suit against the correct party. Nevertheless, in the event that the wrong party is named, under
the right circumstances, there may be a remedy.


© 2013 Nissenbaum Law Group, LLC

Is an Indirect Benefactor from a Nonprofit Organization Considered a “Beneficiary” Under the New Jersey Charitable Immunity Act?

Who should be considered a beneficiary under the New Jersey Charitable Immunity Act?

In Larissa Sapia and Joseph Sapia v. Hunterdon County YMCA, L-10265-09 (N.J. Super. App. Div. August 10, 2012), Larissa Sapia (“Plaintiff”) went to the YMCA (“Defendant”) to examine its facilities with her parents. Plaintiff went with her parents only to act as a translator for them because they did not speak English.  While touring the facilities, Plaintiff slipped on a puddle of water located in front of a water fountain. The fountain was between the men’s and women’s locker room entrances. 

Plaintiff sought damages against Defendant that were caused by the unsafe condition of Defendant’s premises. Defendant claimed its potential personal injury liability was limited by the New Jersey Charitable Immunity Act (“Act”) and moved for summary judgment. The court granted Defendant’s motion. Plaintiff filed a motion for reconsideration with the Superior Court of New Jersey, Appellate Division (“Court”). Plaintiff acknowledged Defendant’s status as a nonprofit tax exempt entity that was organized for charitable purposes. Therefore, the issue considered on appeal was confined to whether Plaintiff was a beneficiary of the charitable works. If it were, it could potentially receive immunity under the Act.

The Court explained that the Act shields charitable entities from liability for negligence in certain circumstances. The Court noted that the grant of immunity under the Act is not mandatory; it is not conditional. However, the Court also noted that the Act is liberally construed so as to afford immunity to nonprofit corporations organized for charitable, educational, or hospital purposes. 

In order for an entity to qualify for charitable immunity it must be:

1) formed for non-profit purposes;

2) organized exclusively for religious, charitable, or educational purposes; and

3) promoted for objective and purposes at the time of the injury to the plaintiff who was then a beneficiary of the charitable works.

The Court elaborated upon who is considered a beneficiary of the charitable works under the Act. The Court explained that beneficiary status does not depend upon a showing that plaintiff personally receives a benefit from the works of the charity. Rather, the issue was whether the entity claiming immunity was engaged in the performance of the charitable objectives that was the purpose of its

The Court considered the following factors:

  • Plaintiff was educated regarding the nature of available services that Defendant offered
    and on Defendant’s proposed goals.
  • Plaintiff’s presence was incidental to the accomplishment of her own objectives, which were
    related to the charity’s beneficence; ensuring her parents could receive the benefits of the facility tour.
  • Defendant was advancing its charitable goals at the time Plaintiff was injured because it
    occurred while walking a guided tour of the facility where Defendant conducted its activities and functions.

Based upon these factors, the Court held that Plaintiff benefited from the charity’s works. Therefore, she was a beneficiary of Defendant. Thus, the Court affirmed Defendant’s motion to dismiss.

A lesson to be noted is that nonprofits may be immune from personal injury claims even if the person
injured is on the premises for purposes that do not directly benefit them.


© 2012 Nissenbaum Law Group, LLC

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