NJSBA Daily Briefing: 09/18/2026

Legal News

Capitol Report: NJSBA-Supported Bill Requiring Representation by an Attorney in PIP Arbitration Hearings Clears Assembly Panel

Read this week’s Capitol Report for updates on a state bill that would require parties in arbitration hearings involving personal injury protection claims to be represented by New Jersey-licensed attorneys, as well as two bills that would classify certain professionals as independent contractors. Read the full report here.

Product Liability Cases Reach 10-Year High, Report Finds

Individual product liability filings increased to 5,692 in 2025, a 31% year-over-year increase and the highest annual total in a decade, according to a new report from legal analytics platform Lex Machina. Read the ABA Journal article here.

NJSBA Leadership Academy Application Deadline Extended

There’s still time to apply! The deadline for the 2026-2027 NJSBA Leadership Academy has been extended to Sept. 23. The Leadership Academy provides intensive learning, career planning, knowledge sharing and networking opportunities essential to leadership in the bar, in the workplace and in the community. Apply here.

Rutgers Law School Launches Online J.D. Program, Expanding Access to a Rutgers Legal Education Nationwide

Beginning in 2027, Rutgers Law School will launch an online J.D. program that combines live online classes, flexible coursework and periodic in-person learning experiences, creating a pathway for students who want to earn a law degree while balancing careers, caregiving responsibilities, military service, community commitments or other personal obligations.

Court Denies MCL Designation Involving Federal No Surprises Act

The state Supreme Court denied an application to designate New Jersey state court litigation involving independent dispute resolution payment determinations under the federal No Surprises Act as multicounty litigation. The decision followed the Court’s consideration of public comments. Read the court notice here.

Supreme Court, Appellate and Third Circuit Decision Summaries

Click on any decision below to get the full opinion – September 17, 2026.

U.S. Court of Appeals for the Third Circuit

Family/Civil Rights – Fourth Amendment Violation

Kindra O'Bryant v. DCP&P – The plaintiffs brought claims alleging that caseworkers with New Jersey’s Division of Child Protection and Permanency violated the Fourth Amendment by entering their residence without a warrant and violated their due process rights by removing children from their parental custody without court authorization when the children did not face a risk of imminent harm. The District Court dismissed the complaint based on qualified immunity. The Third Circuit affirmed the dismissal in most respects. However, it reversed the dismissal of the Fourth Amendment claim and remanded for further proceedings on that claim, finding that some plaintiffs pled plausible violations of clearly established Fourth Amendment law.

New Jersey Appellate Division

Landlord-Tenant – Holdover Tenant Act

Bekir Kulozu vs. Timothy Proudman, et al. (Hudson County and Statewide) – Appellant Timothy Proudman, a former residential co-tenant, appealed the Special Civil Part's final judgment of $8,523.56 plus court costs entered against him in his landlord's favor and the court's approval of the landlord's retention of a $4,500 security deposit. The appellant also appealed the court's denial of relief to him under the Security Deposit Act and its order denying reconsideration. The Appellate Division vacated the monetary judgment against the appellant, holding that the trial court erred under the Holdover Tenant Act in determining that the appellant was liable for post-term rent through a so-called month-to-month "holdover tenancy" in the circumstances presented. In addition, the lease failed to specify with sufficient clarity an obligation by the appellant to pay rent when his ex-wife continued to solely occupy the premises after the 15-month lease term ended and long after the appellant had vacated the premises with timely notice to the landlord, the panel found. The Appellate Division remanded the matter to the trial court for reconsideration of the remaining issues, including those concerning the security deposit.

Real Estate – Commercial Forclosure

Guleria Enterprises, Inc. vs. Multani 1510 RT Gas LLC, et al. (Camden County and Statewide) – The plaintiff Guleria Enterprises, Inc. appealed from four Chancery Division orders in this commercial foreclosure action: an order denying its motion for summary judgment; an order granting the defendant OceanFirst Bank, N.A.'s motion for summary judgment and dismissing the claims against it with prejudice; an order granting the defendant JL Davis Enterprises, Inc.'s motion for summary judgment and dismissing the claims against it with prejudice; and an order dismissing its complaint against the defendant Multani 1510 RT Gas, LLC with prejudice. The litigation stemmed from a series of sales involving a Cherry Hill gas station, car wash and convenience store. The Appellate Division vacated the orders and remanded for further proceedings.