ABC test (New Jersey) · Go Syfert
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ABC test in New Jersey

32 New Jersey opinions name it 3 courts 1957–2026 15 in the last five years

The cases below were cited by New Jersey courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (14)

CaseFollowedCited
Carpet Remnant Warehouse, Inc. v. New Jersey Department of Laborgreen
nj · 1991 · cited in 17 New Jersey opinions naming this issue, 1991–2025
2 sentences

2025The statutory ABC test provides: A-3983-23 10 Services performed by an individual for remuneration shall be deemed to be employment . . . unless and until it is shown to the satisfaction of the division that: (A) Such individual has been and will continue to be free from control or direction over the performance of such service, both under his contract of service and in fact; (B) Such service is either outside the usual course of the business for which such service is performed, or that such service is performed outside of all the places of business of the enterprise for which such service is

2025The statutory ABC test provides: A-3983-23 10 Services performed by an individual for remuneration shall be deemed to be employment . . . unless and until it is shown to the satisfaction of the division that: (A) Such individual has been and will continue to be free from control or direction over the performance of such service, both under his contract of service and in fact; (B) Such service is either outside the usual course of the business for which such service is performed, or that such service is performed outside of all the places of business of the enterprise for which such service is

717
Sam Hargrove v. Sleepy's, LLC (072742)green
nj · 2015 · cited in 14 New Jersey opinions naming this issue, 2017–2026
2 sentences

2024In Hargrove v. Sleepy’s, LLC, the Court adopted the ABC test for determining whether a person is an employee or an independent contractor under the WPL. 220 N.J. 289, 312-16 (2015). (pp. 16-18) 3.

2024In Hargrove v. Sleepy’s, LLC, the Court adopted the ABC test for determining whether a person is an employee or an independent contractor under the WPL. 220 N.J. 289, 312-16 (2015). (pp. 16-18) 3.

714
Trauma Nurses, Inc. v. Board of Reviewgreen
njsuperctappdiv · 1990 · cited in 2 New Jersey opinions naming this issue, 1991–2026
2 sentences

1991Before reviewing the relevant statutory and case law regarding the ABC test, we note that the primary objective of the UCL is to provide a cushion for the workers of New Jersey "against the shocks and rigors of unemployment." Provident Inst. for Sav. in Jersey City v. Division of Employment Sec., 32 N.J. 585, 590 , 161 A. 2d 497 (1960); accord Trauma Nurses, Inc. v. Board of Review, 242 N.J.

1991Before reviewing the relevant statutory and case law regarding the ABC test, we note that the primary objective of the UCL is to provide a cushion for the workers of New Jersey "against the shocks and rigors of unemployment." Provident Inst. for Sav. in Jersey City v. Division of Employment Sec., 32 N.J. 585, 590 , 161 A. 2d 497 (1960); accord Trauma Nurses, Inc. v. Board of Review, 242 N.J.

12
Gilchrist v. Division of Employment Securitygreen
njsuperctappdiv · 1957 · cited in 2 New Jersey opinions naming this issue, 1991–2019
2 sentences

2019We have also considered the court's finding that plaintiffs are employees because defendants failed to present sufficient evidence establishing the ABC test's third prong—that plaintiffs constitute "enterprise[s] that exist[] and can continue to exist independently of and apart from the particular service relationship." Hargrove, 220 N.J. at 306 (quoting Gilchrist v. Div. of Emp't Sec., 48 N.J.

2019We have also considered the court's finding that plaintiffs are employees because defendants failed to present sufficient evidence establishing the ABC test's third prong—that plaintiffs constitute "enterprise[s] that exist[] and can continue to exist independently of and apart from the particular service relationship." Hargrove, 220 N.J. at 306 (quoting Gilchrist v. Div. of Emp't Sec., 48 N.J.

12
Lowe v. Zarghamigreen
nj · 1999 · cited in 2 New Jersey opinions naming this issue, 2017–2017
2 sentences

2017Kotsovska v. Liebman, 221 N.J. 568 , 116 A.3d 1 (2015) (adopting a “hybrid” approach for determining a worker’s status under the Workers’ Compensation Act); Hargrove v. Sleepy’s, LLC, 220 N.J. 289 , 106 A3d 449 (2015) (concluding that an employee under the Wage Payment Law should be defined according to the so-called “ABC test” under N.J.S.A. 43:21-19(i)(6)); Basil v. Wolf, 193 N.J. 38, 63-66 , 935 A.2d 1154 (2007) (utilizing a control test to determine that an insurer was not vicariously liable for the negligence of the physi- eian it hired to examine a claimant); Lowe v. Zarghami, 158 N.J. 6

2017Kotsovska v. Liebman, 221 N.J. 568 , 116 A.3d 1 (2015) (adopting a “hybrid” approach for determining a worker’s status under the Workers’ Compensation Act); Hargrove v. Sleepy’s, LLC, 220 N.J. 289 , 106 A3d 449 (2015) (concluding that an employee under the Wage Payment Law should be defined according to the so-called “ABC test” under N.J.S.A. 43:21-19(i)(6)); Basil v. Wolf, 193 N.J. 38, 63-66 , 935 A.2d 1154 (2007) (utilizing a control test to determine that an insurer was not vicariously liable for the negligence of the physi- eian it hired to examine a claimant); Lowe v. Zarghami, 158 N.J. 6

12
Basil v. Wolfgreen
· 2007 · cited in 2 New Jersey opinions naming this issue, 2017–2017
2 sentences

2017Kotsovska v. Liebman, 221 N.J. 568 , 116 A.3d 1 (2015) (adopting a “hybrid” approach for determining a worker’s status under the Workers’ Compensation Act); Hargrove v. Sleepy’s, LLC, 220 N.J. 289 , 106 A3d 449 (2015) (concluding that an employee under the Wage Payment Law should be defined according to the so-called “ABC test” under N.J.S.A. 43:21-19(i)(6)); Basil v. Wolf, 193 N.J. 38, 63-66 , 935 A.2d 1154 (2007) (utilizing a control test to determine that an insurer was not vicariously liable for the negligence of the physi- eian it hired to examine a claimant); Lowe v. Zarghami, 158 N.J. 6

2017Kotsovska v. Liebman, 221 N.J. 568 , 116 A.3d 1 (2015) (adopting a “hybrid” approach for determining a worker’s status under the Workers’ Compensation Act); Hargrove v. Sleepy’s, LLC, 220 N.J. 289 , 106 A3d 449 (2015) (concluding that an employee under the Wage Payment Law should be defined according to the so-called “ABC test” under N.J.S.A. 43:21-19(i)(6)); Basil v. Wolf, 193 N.J. 38, 63-66 , 935 A.2d 1154 (2007) (utilizing a control test to determine that an insurer was not vicariously liable for the negligence of the physi- eian it hired to examine a claimant); Lowe v. Zarghami, 158 N.J. 6

12
Henry v. Rahway State Prisongreen
nj · 1980 · cited in 1 New Jersey opinions naming this issue, 2024–2024
2 sentences

2024He argues the ABC test must be conducted despite an agreement—professional services contract—because an "agreement . . . alone cannot supplant the determination and review of the substance of facts determining whether someone is an employee or independent contractor." Alternatively, he contends N.J.S.A. 43:15A-7.2(a) and (b) must have been "intended to be conjunctive and determinations are required under 7.2(a) and 7.2(b)." Thus, Santore argues, "either the [s]tatute is improper or being misinterpreted." A-0308-23 6 "Courts have a limited role in reviewing a decision of an administrative agenc

2024He argues the ABC test must be conducted despite an agreement—professional services contract—because an "agreement . . . alone cannot supplant the determination and review of the substance of facts determining whether someone is an employee or independent contractor." Alternatively, he contends N.J.S.A. 43:15A-7.2(a) and (b) must have been "intended to be conjunctive and determinations are required under 7.2(a) and 7.2(b)." Thus, Santore argues, "either the [s]tatute is improper or being misinterpreted." A-0308-23 6 "Courts have a limited role in reviewing a decision of an administrative agenc

11
Robert Lavezzi v. State of N.J. (072856)green
nj · 2014 · cited in 1 New Jersey opinions naming this issue, 2024–2024
2 sentences

2024"An appellate court affords a 'strong presumption of reasonableness' to an administrative agency's exercise of its statutorily delegated responsibilities." Lavezzi v. State, 219 N.J. 163, 171 (2014) (quoting City of Newark v. Nat.

2024"An appellate court affords a 'strong presumption of reasonableness' to an administrative agency's exercise of its statutorily delegated responsibilities." Lavezzi v. State, 219 N.J. 163, 171 (2014) (quoting City of Newark v. Nat.

11
Schomp v. Fuller Brush Co.green
nj · 1940 · cited in 1 New Jersey opinions naming this issue, 2022–2022
2 sentences

2022The ABC test presumes a worker is an employee, Hargrove, 220 N.J. at 305 , and if the record fails to establish any one prong, the Department must deem the worker an employee, Schomp, 124 N.J.L. at 489 .

2022The ABC test presumes a worker is an employee, Hargrove, 220 N.J. at 305 , and if the record fails to establish any one prong, the Department must deem the worker an employee, Schomp, 124 N.J.L. at 489 .

11
United States v. Rosenwassergreen
scotus · 1945 · cited in 1 New Jersey opinions naming this issue, 2021–2021
2 sentences

2021The Court concluded that the New Jersey department's reliance on the ABC test, which requires that independent contractors satisfy all three factors A, B, and C, 5 The United States Supreme Court has stated, regarding that definition, "A broader or more comprehensive coverage of employees within the stated categories would be difficult to frame." United States v. Rosenwasser, 323 U.S. 360, 362 (1945).

2021The Court concluded that the New Jersey department's reliance on the ABC test, which requires that independent contractors satisfy all three factors A, B, and C, 5 The United States Supreme Court has stated, regarding that definition, "A broader or more comprehensive coverage of employees within the stated categories would be difficult to frame." United States v. Rosenwasser, 323 U.S. 360, 362 (1945).

11
Philadelphia Newspapers, Inc. v. Board of Reviewgreen
njsuperctappdiv · 2007 · cited in 1 New Jersey opinions naming this issue, 2019–2019
2 sentences

2019Newspapers, Inc. v. Bd. of Review, 397 N.J.

2019Newspapers, Inc. v. Bd. of Review, 397 N.J.

11
Boudrot v. Director, Division of Taxationgreen
njtaxct · 1982 · cited in 1 New Jersey opinions naming this issue, 1999–1999
1 sentence

1999N.J.S.A. 43:21 — 19(I)(6)(A), (B), and (C), (the so-called “ABC test”), Boudrot v. Director, Div. of Taxation, 4 N.J.Tax 268, 274 (1982), Poppe v. Director, Div. of Taxation, 6 N.J.Tax 108 (1983) (discussing common tests).

11
Koza v. New Jersey Department of Laborgreen
njsuperctappdiv · 1995 · cited in 1 New Jersey opinions naming this issue, 1998–1998
2 sentences

1998In the earlier appeal in this matter, reported at 282 N.J.Super. 560 , 660 A.2d 1231 (App.Div.1995), we determined that petitioner had satisfied parts A and B of the “ABC test,” N.J.S.A. 43:21-19(i)(6)(A),(B) and (C).

1998In the earlier appeal in this matter, reported at 282 N.J.Super. 560 , 660 A.2d 1231 (App.Div.1995), we determined that petitioner had satisfied parts A and B of the “ABC test,” N.J.S.A. 43:21-19(i)(6)(A),(B) and (C).

11
Electrolux Corporation v. Board of Reviewgreen
nj · 1942 · cited in 1 New Jersey opinions naming this issue, 1991–1991
2 sentences

1991See Electrolux Corp. v. Board of Review, 129 N.J.L. 157, 159 , 28 A. 2d 209 (E & A 1942) ( Electrolux Corp. II); Gilchrist, supra, 48 N.J.

1991See Electrolux Corp. v. Board of Review, 129 N.J.L. 157, 159 , 28 A. 2d 209 (E & A 1942) ( Electrolux Corp. II); Gilchrist, supra, 48 N.J.

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Larsen v. State, Dept. of Employmentgreen
idaho · 1984 · cited in 1 New Jersey opinions naming this issue, 1991–1991
2 sentences

1991But cf. Larsen v. Department of Employment, 106 Idaho 382 , 679 P. 2d 659 (1984) (pipe removers who did not require particular skill or training and did not supply their own equipment were not engaged in independently-established business and were therefore employees); New Sleep v. Department of Employment Sec., 703 P. 2d 289 (Utah 1985) (part-time waterbed installers were not customarily engaged in independently-established trade and were therefore employees).

1991But cf. Larsen v. Department of Employment, 106 Idaho 382 , 679 P. 2d 659 (1984) (pipe removers who did not require particular skill or training and did not supply their own equipment were not engaged in independently-established business and were therefore employees); New Sleep v. Department of Employment Sec., 703 P. 2d 289 (Utah 1985) (part-time waterbed installers were not customarily engaged in independently-established trade and were therefore employees).

11

Also cited on this issue (11)

CaseCitedYears
Estate of Myroslava Kotsovska v. Saul Liebman (073861) green
nj · 2015
2 sentences

2017Kotsovska v. Liebman, 221 N.J. 568 , 116 A.3d 1 (2015) (adopting a “hybrid” approach for determining a worker’s status under the Workers’ Compensation Act); Hargrove v. Sleepy’s, LLC, 220 N.J. 289 , 106 A3d 449 (2015) (concluding that an employee under the Wage Payment Law should be defined according to the so-called “ABC test” under N.J.S.A. 43:21-19(i)(6)); Basil v. Wolf, 193 N.J. 38, 63-66 , 935 A.2d 1154 (2007) (utilizing a control test to determine that an insurer was not vicariously liable for the negligence of the physi- eian it hired to examine a claimant); Lowe v. Zarghami, 158 N.J. 6

2017Kotsovska v. Liebman, 221 N.J. 568 , 116 A.3d 1 (2015) (adopting a “hybrid” approach for determining a worker’s status under the Workers’ Compensation Act); Hargrove v. Sleepy’s, LLC, 220 N.J. 289 , 106 A3d 449 (2015) (concluding that an employee under the Wage Payment Law should be defined according to the so-called “ABC test” under N.J.S.A. 43:21-19(i)(6)); Basil v. Wolf, 193 N.J. 38, 63-66 , 935 A.2d 1154 (2007) (utilizing a control test to determine that an insurer was not vicariously liable for the negligence of the physi- eian it hired to examine a claimant); Lowe v. Zarghami, 158 N.J. 6

22017–2017
Bloom v. Div. of Employment SEC. green
njsuperctappdiv · 1961
2 sentences

2024Ibid.

2024Ibid.

12024–2024
D'Annunzio v. Prudential Insurance Co. of America green
nj · 2007
2 sentences

2021D'Annunzio, 192 N.J. at 122 . 6 Weichert also contends there is no evidence that the department has ever actually applied the ABC test to determine if the WPL or WHL applies to real estate salespersons.

2021D'Annunzio, 192 N.J. at 122 . 6 Weichert also contends there is no evidence that the department has ever actually applied the ABC test to determine if the WPL or WHL applies to real estate salespersons.

12021–2021
State v. Simpson green
njsuperctappdiv · 2003
1 sentence

2019Super. at 453 , 839 A.2d 896 .] Now that ABC's challenge to the Directive has been addressed, we anticipate that bail bond companies, including this plaintiff and all others, will be able to litigate or settle their exoneration claims more efficiently based on the clear standards set forth in the Directive.

12019–2019
Koza v. New Jersey Department of Labor green
njsuperctappdiv · 1998
2 sentences

2000Id. at 443-44 , 704 A. 2d 1310 .

2000Id. at 443-44 , 704 A. 2d 1310 .

12000–2000
Poppe v. Taxation Division Director green
njtaxct · 1983
1 sentence

1999N.J.S.A. 43:21 — 19(I)(6)(A), (B), and (C), (the so-called “ABC test”), Boudrot v. Director, Div. of Taxation, 4 N.J.Tax 268, 274 (1982), Poppe v. Director, Div. of Taxation, 6 N.J.Tax 108 (1983) (discussing common tests).

11999–1999
Steel Pier Amusement Co. v. New Jersey Unemployment Compensation Commission green
nj · 1941
2 sentences

1995The only reported decision in New Jersey applying the ABC test to musicians is Steel Pier Amusement Co. v. Unemployment Compensation Com., 127 N.J.L. 154, 157 , 21 A.2d 767 (Sup.Ct.1941).

1995The only reported decision in New Jersey applying the ABC test to musicians is Steel Pier Amusement Co. v. Unemployment Compensation Com., 127 N.J.L. 154, 157 , 21 A.2d 767 (Sup.Ct.1941).

11995–1995
New Sleep, Inc. v. Department of Employment Security green
utah · 1985
2 sentences

1991But cf. Larsen v. Department of Employment, 106 Idaho 382 , 679 P. 2d 659 (1984) (pipe removers who did not require particular skill or training and did not supply their own equipment were not engaged in independently-established business and were therefore employees); New Sleep v. Department of Employment Sec., 703 P. 2d 289 (Utah 1985) (part-time waterbed installers were not customarily engaged in independently-established trade and were therefore employees).

1991But cf. Larsen v. Department of Employment, 106 Idaho 382 , 679 P.2d 659 (1984) (pipe removers who did not require particular skill or training and did not supply their own equipment were not engaged in independently-established business and were therefore employees); New Sleep v. Department of Employment Sec., 703 P.2d 289 (Utah 1985) (part-time waterbed installers were not customarily engaged in independently-established trade and were therefore employees).

11991–1991
North American Builders, Inc. v. Unemployment Compensation Division, Department of Employment Security green
utah · 1969
2 sentences

1991Div., 22 Utah 2d 338 , 453 P. 2d 142 (1969) (siding installers held to be independent contractors under ABC test).

1991Div., 22 Utah 2d 338 , 453 P. 2d 142 (1969) (siding installers held to be independent contractors under ABC test).

11991–1991
Provident Institution for Savings v. Division of Employment Security green
nj · 1960
2 sentences

1991Before reviewing the relevant statutory and case law regarding the ABC test, we note that the primary objective of the UCL is to provide a cushion for the workers of New Jersey "against the shocks and rigors of unemployment." Provident Inst. for Sav. in Jersey City v. Division of Employment Sec., 32 N.J. 585, 590 , 161 A. 2d 497 (1960); accord Trauma Nurses, Inc. v. Board of Review, 242 N.J.

1991Before reviewing the relevant statutory and case law regarding the ABC test, we note that the primary objective of the UCL is to provide a cushion for the workers of New Jersey "against the shocks and rigors of unemployment." Provident Inst. for Sav. in Jersey City v. Division of Employment Sec., 32 N.J. 585, 590 , 161 A. 2d 497 (1960); accord Trauma Nurses, Inc. v. Board of Review, 242 N.J.

11991–1991
Fuller Brush Co. v. Industrial Commission green
utah · 1940
2 sentences

1957Fuller Brush Co. v. Industrial Commission of Utah, 99 Utah 97 , 104 P. 2d 201 , 129 A. L.

1957Fuller Brush Co. v. Industrial Commission of Utah, 99 Utah 97 , 104 P. 2d 201 , 129 A. L.

11957–1957

Statutes the citing opinions construe

NJ § N.J. Stat. § 43:21-19 (24) NJ § N.J. Stat. § 43:21-1 (13) NJ § N.J. Stat. § 34:11-4.1 (9) NJ § N.J. Stat. § 34:11-56a (7) NJ § N.J. Stat. § 43:21-7 (7) NJ § N.J. Stat. § 45:15-3.2 (4) NJ § N.J. Stat. § 34:11-4.4 (3) NJ § N.J. Stat. § 45:15-14 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 40 (1967–2025) NJ 32 (1957–2026) CT 20 (1980–2022) WA 16 (1994–2024) NY 11 (2002–2025) ME 10 (1987–2013) MA 10 (2002–2026) VT 9 (1981–2018) TX 4 (1999–2022) MN 3 (1946–1995) MT 3 (1988–1989) NE 3 (1983–1997) AZ 2 (1994–2000) OK 2 (2007–2008) AR 2 (2008–2013) TN 2 (2004–2021) IN 2 (1976–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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