New Jersey Supreme Court Landmark Cases

The New Jersey Supreme Court is recognized as one of the leading state courts in the nation. The issues that come before the Court cover a vast array of topics, from the education of children to procedures in criminal trials.

Cases come to the Court because the parties cannot agree. Often the circumstances of the cases are unique. The Court then must consider the unusual and often difficult problem presented and reach a decision that is fair and informed by existing law.

Here are summaries of some of the Court’s most notable cases. More information about these and other landmark decisions rendered by the Court can be found at https://www.njcourts.gov/courts/supreme/vm/scvirtualpic.html#nc

Winberry v. Salisbury (1950) This early decision concerned the question of whether the New Jersey Supreme Court, rather than the Legislature, had the power to govern the “practice and procedure” in the courts of the state. The Court held that the provision in the state constitution authorizing the Supreme Court to enact rules of practice and procedure should be interpreted to prohibit the Legislature from enacting laws that purported to govern practice and procedure in the courts. There is no similar provision in the U.S. Constitution.

Henningsen v. Bloomfield Motors, Inc. (1960) This decision held the manufacturer liable for a defective automobile driven by the plaintiff. The Court declared that both a manufacturer who put a new car into the stream of commerce, promoting its purchase by the public, and the dealer who sold it, would be deemed to accompany that car with an implied warranty that it was reasonably suitable for its intended use. The Court further declared that this warranty extended not only to the buyer, but to members of her family and others using the car with her consent. In effect, the New Jersey Supreme Court was informing manufacturers across America that they could no longer rely upon tightly worded expressed warranties as a shield against consumer claims.

Southern Burlington County NAACP v. Township of Mount Laurel (Mount Laurel I) (1970) An action was brought against Mount Laurel on the grounds that the township’s land use regulations unlawfully excluded low and moderate-income families. The Court held “as a developing municipality, Mount Laurel must, by its land use regulations, make realistically possible the opportunity for an appropriate variety and choice of housing for all categories of people who desire to live there, of course including those of low and moderate income.” This opinion became known as Mount Laurel I.

Southern Burlington County NAACP v. Township of Mount Laurel Mount Laurel II) (1983) Because Mount Laurel failed to implement the provisions of Mount Laurel I, the Court revisited the case in 1983. The decision in what is now known as Mount Laurel II set forth specific requirements that every town in New Jersey must provide its “fair share” of the regional need for low- and moderate-income housing. The decision in Mount Laurel II set forth the critical yet previously unstated principle that all people, including those society deems “poor,” have a right to live anywhere and that municipalities cannot manipulate zoning regulations to preclude people from living in an area solely because of economic status.

Robinson v. Cahill (1976) The Court held that the Public School Education Act of 1975 was facially constitutional and that it complied with the requirement that local school districts be afforded a means of overcoming budget shortfalls. The Court held that the court order that the state and the governor disburse funds to ensure that all children would receive equal educational opportunities was not a violation of the separation of powers because the Court must correct the violation of the plaintiff’s fundamental right to receive a “thorough and efficient” education.

Abbott v. Burke (1985) This case involved a constitutional challenge to the Public School Education Act of 1975. The plaintiffs challenged the plan for funding New Jersey’s constitutional mandate of a through and efficient education through local property taxes. The Court decided that the matter should be handled first at the administrative level and transferred it to the state Commissioner of Education.

In Re: Karen Ann Quinlan (1976) In this case, the Court held that the right to privacy under both the U.S. and New Jersey Constitutions bestowed upon an individual, or guardians acting on the individual’s behalf, a protectable interest against intrusion by the state and established a patient’s right to refuse life-sustaining medical treatments.

In the Matter of Baby M. (1988) In this case, the Court invalidated a surrogate parenting contract between a couple and surrogate mother, calling the intended payment “illegal, perhaps criminal, and potentially degrading to women.” However, the Court granted custody to the couple.

Doe v. Poritz (1995) The Court ruled that bills related to Megan’s Law, including community notification of the presence of a sex offender living in a neighborhood, are constitutional. The Court held that a prosecutor’s decision to provide community notification, including the manner of notification, is subject to judicial review before such notification is given, and that such review is constitutionally required. Lewis v. Harris (2006) The Court held that the state’s marriage laws violated the rights of same sex couples to equal protection under the law. In response, the Legislature created same sex unions.

State v. Henderson (2011) The Court confronted the problem of erroneous identifications in situations in which a witness might honestly identify a person as the culprit but be mistaken. Drawing upon an extensive record of scientific studies and reports, the Court laid down a new framework to assess the reliability of eyewitness identification testimony in New Jersey courts.

State v. Andujar (2021) The Court upheld an Appellate Division opinion overturning a 2017 first-degree murder conviction after finding that the prosecution might have relied on implicit or unconscious bias when it sought to dismiss a prospective juror who is Black. The Court ordered a new trial for the defendant and asked the administrative director of the courts to arrange for a judicial conference to explore the nature of discrimination in the jury selection process.