burden of establishing immunity (New Jersey) · Go Syfert
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burden of establishing immunity in New Jersey

30 New Jersey opinions name it 2 courts 1939–2026 6 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 (11)

CaseFollowedCited
Landwehr v. Landwehrgreen
nj · 1988 · cited in 11 New Jersey opinions naming this issue, 1994–2026
2 sentences

2026The party challenging the inclusion of an asset in the marital estate bears "'the burden of establishing such immunity [from equitable distribution] as to any particular asset.'" Pascale, 140 N.J. at 609 (quoting Landwehr v. Landwehr, 111 N.J. 491, 504 (1988)).

2025"To refute such a presumption, the party seeking exclusion of the asset must bear 'the burden of establishing such immunity [from equitable distribution] as to any particular asset.'" Pascale, 140 N.J. at 609 (quoting Landwehr v. Landwehr, 111 N.J. 491, 504 (1988)).

711
Painter v. Paintergreen
nj · 1974 · cited in 8 New Jersey opinions naming this issue, 1988–2021
2 sentences

2021"The burden of establishing such immunity as to any particular asset will rest upon the spouse who asserts it." Ibid.

2011Ibid, (citing Landwehr v. Landwehr, 111 N.J. 491, 504 , 545 A.2d 738 (1988); Painter v. Painter, 65 N.J. 196, 214 , 320 A.2d 484 (1974) (noting that the burden of establishing immunity of a particular asset from equitable distribution will rest upon the spouse who asserts it)).

28
State v. Berezanskygreen
njsuperctappdiv · 2006 · cited in 2 New Jersey opinions naming this issue, 2017–2018
2 sentences

2018State v. Berezansky, 386 N.J.

2017State v. Berezansky, 386 N.J.

22
Pacifico v. Pacificogreen
nj · 2007 · cited in 2 New Jersey opinions naming this issue, 2011–2025
2 sentences

2011See Pacifico, supra, 190 N.J. at 269 , 920 A. 2d 73 (reiterating that "the burden of establishing immunity from distribution of a particular marital asset or portion of an asset rests upon the spouse who asserts it"). *888 A plenary hearing affords the airing of proofs regarding the nature of the promotion and whether any corresponding pension enhancement was an ordinary increase arising from the joint efforts of the parties during their marriage, or whether the sums are separate assets generated during the post-judgment pre-retirement efforts of defendant excludable from equitable sharing.

2011See Pacifico, supra, 190 N.J. at 269 , 920 A. 2d 73 (reiterating that "the burden of establishing immunity from distribution of a particular marital asset or portion of an asset rests upon the spouse who asserts it"). *888 A plenary hearing affords the airing of proofs regarding the nature of the promotion and whether any corresponding pension enhancement was an ordinary increase arising from the joint efforts of the parties during their marriage, or whether the sums are separate assets generated during the post-judgment pre-retirement efforts of defendant excludable from equitable sharing.

12
Dotsko v. Dotskogreen
njsuperctappdiv · 1990 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021Ibid.; Dotsko v. Dotsko, 244 N.J.

11
State v. Tsetsekasgreen
njsuperctappdiv · 2009 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020State v. Tsetsekas, 411 N.J.

11
Weiss v. Weissgreen
njsuperctappdiv · 1988 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020Weiss v. Weiss, 226 N.J.

11
Jecker v. Hidden Valley, Inc.green
njsuperctappdiv · 2011 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019Jecker v. Hidden Valley, Inc., 422 N.J.

11
Gilchinsky v. NATIONAL WESTMINISTER BANKgreen
nj · 1999 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019In determining whether the circumstances of a particular transaction give rise to the conclusion that the transferor intended to thwart or evade creditors, courts generally look to factors commonly referred to A-5450-15T4 15 as "badges of fraud." "Badges of fraud" represent circumstances that so frequently accompany fraudulent transfers that their presence gives rise to an inference of intent. [ 159 N.J. at 475-76 (alteration in the original) (citations omitted)] The plaintiff bears the burden of establishing a claim under the UFTA by clear and convincing evidence.

11
Welsh v. Wisconsingreen
scotus · 1984 · cited in 1 New Jersey opinions naming this issue, 2013–2013
2 sentences

2013See Welsh, supra, 466 U.S. at 750 , 104 S.Ct. at 2098 , 80 L.Ed.2d at 743 .

2013See Welsh, supra, 466 U.S. at 750 , 104 S.Ct. at 2098 , 80 L.Ed.2d at 743 .

11
Benjamin v. Blakegreen
nj · 1938 · cited in 1 New Jersey opinions naming this issue, 1957–1957
1 sentence

1957Benjamin v. Blake, 121 N.J.L. 10, 12 ( Sup. Ct. 1938).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Pascale v. Pascale green
nj · 1995
2 sentences

2026The party challenging the inclusion of an asset in the marital estate bears "'the burden of establishing such immunity [from equitable distribution] as to any particular asset.'" Pascale, 140 N.J. at 609 (quoting Landwehr v. Landwehr, 111 N.J. 491, 504 (1988)).

2025"To refute such a presumption, the party seeking exclusion of the asset must bear 'the burden of establishing such immunity [from equitable distribution] as to any particular asset.'" Pascale, 140 N.J. at 609 (quoting Landwehr v. Landwehr, 111 N.J. 491, 504 (1988)).

91998–2026
State v. Gerald green
nj · 1988
2 sentences

2001State v. Gerald, 113 N.J. 40, 118 , 549 A. 2d 792 (1988).

2001State v. Gerald, 113 N.J. 40, 118 , 549 A. 2d 792 (1988).

12001–2001
Kikkert v. Kikkert green
njsuperctappdiv · 1981
2 sentences

1995In Kikkert, supra, this Court approved of the Appellate Division’s characterization of a pension benefit as “the result of direct or indirect efforts *610 expended by one or both parties to the marriage — it is additional compensation for services rendered for the employer and a right acquired during the marriage.” 177 N.J.Super. at 476 , 427 A.2d 76 .

1995In Kikkert, supra, this Court approved of the Appellate Division’s characterization of a pension benefit as “the result of direct or indirect efforts *610 expended by one or both parties to the marriage — it is additional compensation for services rendered for the employer and a right acquired during the marriage.” 177 N.J.Super. at 476 , 427 A.2d 76 .

11995–1995
Perkins v. Perkins green
njsuperctappdiv · 1978
1 sentence

1994N.J.S.A. 2A:34-23; Perkins v. Perkins, 159 N.J.

11994–1994
State v. Lynch yellow
nj · 1943
1 sentence

1980Id. at 256-257 .

11980–1980
In re estate of Bottomley green
njsuperctappdiv · 1920
1 sentence

1939In re Bottomley, 92 N.J.

11939–1939

Statutes the citing opinions construe

NJ § N.J. Stat. § 2A:34-23 (9) NJ § N.J. Stat. § 2A:34-23.1 (7) NJ § N.J. Stat. § 2C:44-1 (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 195 (1918–2026) TX 93 (1906–2026) MT 83 (1998–2025) IL 81 (1904–2026) NY 80 (1888–2025) PA 54 (1924–2024) OH 53 (1977–2026) LA 42 (1933–2024) MI 41 (1934–2022) CO 39 (1975–2026) WA 39 (1912–2020) GA 35 (1923–2023) NJ 30 (1939–2026) AZ 28 (1971–2025) ID 24 (1924–2024) IN 24 (1913–2025) CT 21 (1912–2021) NM 20 (1969–2025) IA 20 (1879–2023) MN 20 (1904–2025) MO 18 (1891–2021) SC 17 (1962–2026) OR 15 (1984–2025) MS 15 (1962–2017) VA 15 (1944–2022) WV 15 (1962–2026) KS 14 (1898–2026) TN 13 (1996–2025) MD 13 (1916–2026) FL 12 (1962–2024) AL 10 (1980–2005) ND 9 (1927–2024) AR 8 (1988–2012) NC 7 (1957–2020) WY 7 (1981–2026) MA 7 (1980–2012) WI 7 (2001–2026) SD 6 (1963–2015) HI 5 (1980–2023) DE 5 (1970–2025) VT 5 (1946–1982) OK 4 (1950–1976) NV 4 (1973–2018) KY 4 (1923–2016) NE 3 (1987–2004) AK 3 (1978–1994) UT 2 (1941–2017) DC 2 (1972–2001) NH 2 (1982–1983)

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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