sanction violation (New Jersey) · Go Syfert
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sanction violation in New Jersey

25 New Jersey opinions name it 2 courts 1988–2025 4 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 (12)

CaseFollowedCited
State v. Samander S. Dabas (069498)green
nj · 2013 · cited in 6 New Jersey opinions naming this issue, 2017–2022
2 sentences

2022Super. 124 , 137 (App. Div. 2017) (citing State v. Dabas, 215 N.J. 114, 141 (2013)) ("We recognize that trial courts are vested with the discretion to fashion an appropriate sanction for a violation of discovery obligations.").

2018The prosecutor insisted the DNA evidence linking defendant to the scene of the crime was "extraordinarily probative" and "extraordinarily important to the State." "We recognize that trial courts are vested with the discretion to fashion an appropriate sanction for a violation of discovery obligations." Richardson , 452 N.J.Super. at 137 , 171 A.3d 1270 (citing State v. Dabas , 215 N.J. 114 , 141, 71 A.3d 814 (2013) ).

36
Abtrax Pharmaceuticals, Inc. v. Elkins-Sinn, Inc.green
nj · 1995 · cited in 4 New Jersey opinions naming this issue, 2005–2021
2 sentences

2021See, e.g., Kosmowski, 175 N.J. at 575 ; see also Abtrax Pharms., Inc. v. Elkins-Sinn, Inc., 139 N.J. 499, 514 (1995) (explaining the determination of a sanction for the violation of a court order requires consideration of whether the violation is willful).

2016“In assessing the appropriate sanction for the violation of one of its orders, the court must consider a number of factors, including whether the plaintiff acted willfully and whether the defendant suffered harm, and if so, to what degree.” Gonzalez, supra, 185 N.J. at 115 , 881 A.2d 719 (citing Abtrax, supra, 139 N.J. at 514 , 655 A.2d 1368 ).

34
Alaska Steamship Co. v. Pettersongreen
scotus · 1954 · cited in 2 New Jersey opinions naming this issue, 1988–1989
2 sentences

1989Burger, Abuses of Discovery: Judges are Correcting the Problem, 20 Trial 18 (1984). [2] While the United States Supreme Court has upheld the preclusion of defense witness testimony as a sanction for defense counsel's discovery violations, Taylor v. Illinois, 484 U.S. 400 , 108 S.Ct. 646 , 98 L.Ed. 2d 798 (1988), our Court has not yet had occasion to decide whether such a harsh procedure would violate our State Constitution.

1989While the United States Supreme Court has upheld the preclusion of defense witness testimony as a sanction for defense counsel's discovery violations, Taylor v. Illinois, 484 U.S. 400 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988), our Court has not yet had occasion to decide whether such a harsh procedure would violate our State Constitution.

22
Gonzalez v. Safe & Sound Security Corp.green
nj · 2005 · cited in 6 New Jersey opinions naming this issue, 2012–2025
2 sentences

2025"In assessing the appropriate sanction for the violation of one of its orders, the court must consider a number of factors, including whether the plaintiff acted willfully and whether the defendant suffered harm, and if so, to what degree." Williams, 226 N.J. at 128 (quoting Gonzalez, 185 N.J. at 115 ).

2025"In assessing the appropriate sanction for the violation of one of its orders, the court must consider a number of factors, including whether the plaintiff acted willfully and whether the defendant suffered harm, and if so, to what degree." Williams, 226 N.J. at 128 (quoting Gonzalez, 185 N.J. at 115 ).

16
Taylor v. Illinoisgreen
scotus · 1988 · cited in 2 New Jersey opinions naming this issue, 1988–1989
2 sentences

1989While the United States Supreme Court has upheld the preclusion of defense witness testimony as a sanction for defense counsel's discovery violations, Taylor v. Illinois, 484 U.S. 400 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988), our Court has not yet had occasion to decide whether such a harsh procedure would violate our State Constitution.

1989While the United States Supreme Court has upheld the preclusion of defense witness testimony as a sanction for defense counsel's discovery violations, Taylor v. Illinois, 484 U.S. 400 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988), our Court has not yet had occasion to decide whether such a harsh procedure would violate our State Constitution.

12
State v. Robert J. Stein(074466)green
nj · 2016 · cited in 1 New Jersey opinions naming this issue, 2022–2022
1 sentence

2022"A trial court's resolution of a discovery issue is entitled to substantial deference and will not be overturned absent an abuse of discretion." State v. Stein, 225 N.J. 582, 593 (2016).

11
Kosmowski v. Atlantic City Medical Centergreen
nj · 2003 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021See, e.g., Kosmowski, 175 N.J. at 575 ; see also Abtrax Pharms., Inc. v. Elkins-Sinn, Inc., 139 N.J. 499, 514 (1995) (explaining the determination of a sanction for the violation of a court order requires consideration of whether the violation is willful).

11
Zaccardi v. Beckergreen
njsuperctappdiv · 1978 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021Dismissal of a complaint or the striking of an answer with prejudice as a sanction for a violation of a court rule or order "is imposed not only to penalize those whose conduct warrant it, but to deter others who [might] be tempted to violate the rules absent such a deterrent." Zaccardi v. Becker, 162 N.J.

11
State v. WBgreen
nj · 2011 · cited in 1 New Jersey opinions naming this issue, 2013–2013
2 sentences

2013See, e.g., W.B., supra, 205 N.J. at 597, 609 , 17 A.3d 187 (holding “an adverse inference charge may be given when a police officer destroys his or her investigatory notes before trial”).

2013See, e.g., W.B., supra, 205 N.J. at 597, 609 , 17 A.3d 187 (holding “an adverse inference charge may be given when a police officer destroys his or her investigatory notes before trial”).

11
Gilbert v. Californiagreen
scotus · 1967 · cited in 1 New Jersey opinions naming this issue, 1989–1989
2 sentences

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

11
Fisher v. United Statesgreen
scotus · 1976 · cited in 1 New Jersey opinions naming this issue, 1989–1989
2 sentences

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

11
United States v. Doegreen
scotus · 1984 · cited in 1 New Jersey opinions naming this issue, 1989–1989
2 sentences

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

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 (15)

CaseCitedYears
State v. Williams green
njsuperctappdiv · 1989
2 sentences

2019We concluded "that when the Legislature expressly stated in N.J.S.A. 2C:45-3(a)(4) that the sanction for a violation of probation (other than for the inherent criminality of the act) would be a revocation of probation, it intended that a defendant would [not] be subject to a new indictment for contempt in addition to the punishment for the original offense." Id. at 93 , 560 A.2d 100 .

2019We concluded "that when the Legislature expressly stated in N.J.S.A. 2C:45-3(a)(4) that the sanction for a violation of probation (other than for the inherent criminality of the act) would be a revocation of probation, it intended that a defendant would [not] be subject to a new indictment for contempt in addition to the punishment for the original offense." Id. at 93 , 560 A.2d 100 .

22019–2019
State v. Bradshaw green
nj · 2008
2 sentences

2009Bradshaw, supra, 195 N.J. at 507-08 , 950 A.2d 889 (stating court should consider prejudice to both parties, whether sanction other than preclusion will preserve policy of rule, and whether failure to give notice “was willful and intended to gain a tactical advantage”).

2009Bradshaw, supra, 195 N.J. at 507-08 , 950 A.2d 889 (stating court should consider prejudice to both parties, whether sanction other than preclusion will preserve policy of rule, and whether failure to give notice “was willful and intended to gain a tactical advantage”).

22009–2009
Lamar Williams v. American Auto Logistics(076004) green
nj · 2016
1 sentence

2025"In assessing the appropriate sanction for the violation of one of its orders, the court must consider a number of factors, including whether the plaintiff acted willfully and whether the defendant suffered harm, and if so, to what degree." Williams, 226 N.J. at 128 (quoting Gonzalez, 185 N.J. at 115 ).

12025–2025
New Jersey Division of Youth & Family Services v. M.G. green
njsuperctappdiv · 2012
1 sentence

2019"The Supreme Court has instructed that the assessment of the appropriate sanction for the violation of an order requires consideration of 'a number of factors, including whether the plaintiff acted willfully and whether the defendant suffered harm, and if so, to what degree.'" Id. at 171 (quoting Gonzalez v. Safe & Sound Sec.

12019–2019
In re Accutane Litigation green
nj · 2017
1 sentence

2018The prosecutor insisted the DNA evidence linking defendant to the scene of the crime was "extraordinarily probative" and "extraordinarily important to the State." "We recognize that trial courts are vested with the discretion to fashion an appropriate sanction for a violation of discovery obligations." Richardson , 452 N.J.Super. at 137 , 171 A.3d 1270 (citing State v. Dabas , 215 N.J. 114 , 141, 71 A.3d 814 (2013) ).

12018–2018
Milne v. Goldenberg green
njsuperctappdiv · 2012
1 sentence

2017Ibid.

12017–2017
De Vitis v. New Jersey Racing Com'n green
njsuperctappdiv · 1985
2 sentences

2002Because racing is accompanied by legalized gambling it “strongly impaet[s] the public interest.” DeVitis v. New Jersey Racing Commission, 202 N.J.Super. 484, 490 , 495 A.2d 457 (App.Div.), certif. denied, 102 N.J. 337 , 508 A.2d 213 (.1985).

2002Because racing is accompanied by legalized gambling it “strongly impaet[s] the public interest.” DeVitis v. New Jersey Racing Commission, 202 N.J.Super. 484, 490 , 495 A.2d 457 (App.Div.), certif. denied, 102 N.J. 337 , 508 A.2d 213 (.1985).

12002–2002
Manorcare Health Services, Inc. v. Osmose Wood Preserving, Inc. green
njsuperctappdiv · 2001
1 sentence

2002Ibid.

12002–2002
De Vitis v. New Jersey Racing Commission green
nj · 1985
2 sentences

2002Because racing is accompanied by legalized gambling it “strongly impaet[s] the public interest.” DeVitis v. New Jersey Racing Commission, 202 N.J.Super. 484, 490 , 495 A.2d 457 (App.Div.), certif. denied, 102 N.J. 337 , 508 A.2d 213 (.1985).

2002Because racing is accompanied by legalized gambling it “strongly impaet[s] the public interest.” DeVitis v. New Jersey Racing Commission, 202 N.J.Super. 484, 490 , 495 A.2d 457 (App.Div.), certif. denied, 102 N.J. 337 , 508 A.2d 213 (.1985).

12002–2002
State v. Williams green
njsuperctappdiv · 1995
2 sentences

1998In reaching her decision, the trial judge particularly noted that dismissal with prejudice was the ultimate sanction for violation of court rule or order, and that it is normally only imposed “when no lesser sanction will erase the prejudice suffered by the nondelinquent party.” However, she distinguished this case from cases where dismissal with prejudice was not ordered to preserve a “blameless plaintiffs claim,” and particularly noted, citing State v. Williams, 286 N.J.Super. 507 , 669 A.2d 867 (Law Div.1995), that “the objects to be achieved in a forfeiture action stand in contrast to the

1998In reaching her decision, the trial judge particularly noted that dismissal with prejudice was the ultimate sanction for violation of court rule or order, and that it is normally only imposed “when no lesser sanction will erase the prejudice suffered by the nondelinquent party.” However, she distinguished this case from cases where dismissal with prejudice was not ordered to preserve a “blameless plaintiffs claim,” and particularly noted, citing State v. Williams, 286 N.J.Super. 507 , 669 A.2d 867 (Law Div.1995), that “the objects to be achieved in a forfeiture action stand in contrast to the

11998–1998
Boyd v. United States red
scotus · 1886
2 sentences

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

11989–1989
Schmerber v. California green
scotus · 1966
2 sentences

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

11989–1989
United States v. Wade green
scotus · 1967
2 sentences

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

11989–1989
Braswell v. United States green
scotus · 1988
2 sentences

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

11989–1989
Matter of Grand Jury Proceedings of Guarino green
nj · 1986
1 sentence

1989See id. at ___, 108 S.Ct. at 657, 98 L.Ed. 2d at 817 (Brennan, J., dissenting) ("[A]t least where a criminal defendant is not personally responsible for the discovery violation, alternative sanctions are not only adequate to correct and deter discovery violations but are far superior to the arbitrary and disproportionate penalty imposed by the preclusion sanction."). [3] Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed. 2d 1178 (1967) (handwriting exemplars); United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed. 2d 1149 (1967) (voice exemplars); Schmerber v. California, 3

11989–1989

Statutes the citing opinions construe

NJ § N.J. Stat. § 2A:162-15 (4) NJ § N.J. Stat. § 2A:162-22 (3) NJ § N.J. Stat. § 2C:15-1 (3) NJ § N.J. Stat. § 2C:5-1 (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

OH 105 (1988–2026) MD 86 (1978–2025) IL 70 (1893–2026) NY 48 (1884–2026) FL 40 (1982–2025) TX 38 (1932–2024) AZ 35 (1954–2025) IA 32 (1919–2022) WA 31 (1914–2024) CA 29 (1986–2026) NJ 25 (1988–2025) NH 22 (1998–2025) UT 20 (2001–2026) IN 20 (1981–2020) OR 18 (1981–2026) CT 16 (1874–2024) CO 15 (1986–2025) MI 15 (1982–2023) MO 14 (1982–2012) PA 12 (1977–2024) WI 12 (1993–2020) NC 9 (1980–2015) MN 8 (1986–2013) ND 8 (1999–2003) AK 7 (1985–2025) KY 7 (2009–2025) KS 7 (1999–2022) LA 6 (1988–2017) MA 6 (1987–2025) RI 6 (1983–2016) NM 6 (1998–2018) HI 5 (1978–2021) DC 5 (1989–2016) NE 5 (1991–2021) TN 5 (2000–2024) NV 4 (1976–2022) ME 4 (1979–2002) WY 4 (2013–2026) GA 3 (1991–2012) AR 3 (1991–2023) VA 3 (1905–2013) MS 3 (1874–2018) DE 3 (1972–2011) WV 2 (1983–1991)

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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