light claim in New Jersey

20 New Jersey opinions name it 2 courts 1949–2026 5 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 (10)

Case	Followed	Cited
Romaine v. Kallingergreen nj · 1988 · cited in 4 New Jersey opinions naming this issue, 2004–2025 2 sentences 2025To succeed on a false light claim, a plaintiff must prove that: (1) “the false light in which the [plaintiff] was placed would be highly offensive to a reasonable person,” and (2) the defendant “had knowledge of or acted in reckless disregard as to the falsity of the publicized 12 matter and the false light in which the [plaintiff] would be placed.” Id. at 294 (quoting Restatement (Second) of Torts § 652E (Am. 2025To succeed on a false light claim, a plaintiff must prove that: (1) “the false light in which the [plaintiff] was placed would be highly offensive to a reasonable person,” and (2) the defendant “had knowledge of or acted in reckless disregard as to the falsity of the publicized 12 matter and the false light in which the [plaintiff] would be placed.” Id. at 294 (quoting Restatement (Second) of Torts § 652E (Am.	2	4
GD v. Kennygreen njsuperctappdiv · 2009 · cited in 2 New Jersey opinions naming this issue, 2025–2026 2 sentences 2026As argued in her merits brief, plaintiff's false light claim against the Township defendants was premised on the forcible removal from her home by police "yelling and threatening to carry her if she refused to walk suggest[ing] to all that plaintiff was in need of involuntary commitment."9 To sustain a false light claim, a plaintiff must show: "(1) the false light in which the other was placed would be highly offensive to a reasonable person; and (2) the actor had knowledge of or acted in reckless disregard as to the falsity of the publicized matter and the false light in which the other would 2025Even if we were to accept plaintiff's argument that this is not actually a false light claim as pleaded, but rather a public disclosure of a private fact claim, with a two-year statute of limitations, his claim would still fail, because any prior conviction "is certainly not private as all criminal arrests and convictions A-2366-23 16 are matters of public record." G.D. v. Kenny, 411 N.J.	2	2
DeAngelis v. Hillgreen nj · 2004 · cited in 2 New Jersey opinions naming this issue, 2020–2025 2 sentences 2025Inst. 1977).] A-0409-23 14 "A false light claim against a public official [is] similar to a defamation claim [in that they both] utilize[] the actual malice standard." DeAngelis v. Hill, 180 N.J. 1, 19 (2004). 2020See DeAngelis v. Hill, 180 N.J. 1, 19 (2004).	2	2
Hustler Magazine, Inc. v. Falwellgreen scotus · 1988 · cited in 2 New Jersey opinions naming this issue, 2002–2012 2 sentences 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)). 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)).	2	2
Leang v. Jersey City Board of Educationgreen nj · 2009 · cited in 2 New Jersey opinions naming this issue, 2025–2026 2 sentences 2026Super. 176, 195 (App. Div. 2009) (emphasis added) (quoting Leang, 198 N.J. at 589 ). 2025To analyze plaintiff's false light claim, we consider two elements: "(1) 'the false light in which the other was placed would be highly offensive to a reasonable person'; and (2) 'the actor had knowledge of or acted in reckless disregard as to the falsity of the publicized matter and the false light in which the other would be placed.'" Leang v. Jersey City Bd. of Educ., 198 N.J. 557, 589 (2009) (quoting Romaine v. Kallinger, 109 N.J. 282, 294 (1988)). "[A] false-light claim requires that the offending party make 'a major misrepresentation of plaintiff's character, history, activities, or beli	1	2
G.D. v. Kennygreen nj · 2011 · cited in 2 New Jersey opinions naming this issue, 2025–2025 2 sentences 2025To analyze plaintiff's false light claim, we consider two elements: "(1) 'the false light in which the other was placed would be highly offensive to a reasonable person'; and (2) 'the actor had knowledge of or acted in reckless disregard as to the falsity of the publicized matter and the false light in which the other would be placed.'" Leang v. Jersey City Bd. of Educ., 198 N.J. 557, 589 (2009) (quoting Romaine v. Kallinger, 109 N.J. 282, 294 (1988)). "[A] false-light claim requires that the offending party make 'a major misrepresentation of plaintiff's character, history, activities, or beli 2025As the Court in G.D. noted, when disposing of a false light claim, it is "essentially the same" as a defamation claim, "[t]ruth may be personally embarrassing and offensive to some, but it remains a defense [to both claims]." 205 N.J. at 308 .	1	2
Swan v. Boardwalk Regency Corp.green njsuperctappdiv · 2009 · cited in 1 New Jersey opinions naming this issue, 2025–2025 2 sentences 2025Flannery notes that Swan, in reliance upon Rumbauskas, “rightfully concluded that the one-year statute 5 of limitations governing defamation actions would be applied in a false light claim that was ‘clearly grounded in allegations which were defamatory in nature.’” (quoting Swan, 407 N.J. 2025Id. at 111, 114. 9 The Appellate Division affirmed the trial court’s dismissal of the false light claim for falling outside the one-year statute of limitations under N.J.S.A. 2A:14-3, referencing that the “motion judge could ‘perceive no rationale for concluding that the Legislature intended that a longer statute of limitations would apply’ to a false light claim . . . which was similar to defamation in that it ‘subject[ed] the victim to the consequences of defamation without the explicit nature of the claim.’” Id. at 121 (alteration in original).	1	1
Anderson v. Liberty Lobby, Inc.green scotus · 1986 · cited in 1 New Jersey opinions naming this issue, 2012–2012 2 sentences 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)). 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)).	1	1
State v. Leonardisgreen nj · 1976 · cited in 1 New Jersey opinions naming this issue, 1977–1977 2 sentences 1977See R. 3:28(c)(3). [1] (1) The power of the Supreme Court, in the exercise of its adjudicative function, to declare the authority of the courts of this State to divert a criminal proceeding, after a hearing, without the consent of the prosecutor, in the light of the doctrine of separation of powers; (2) The power of the Supreme Court, in the exercise of its rule-making power, to declare the authority of the courts of this State to divert a criminal proceeding without the consent of the prosecutor; (3) In respect of both of the foregoing, whether there is any distinction between proceedings pos 1977See R. 3:28(c)(3). [1] (1) The power of the Supreme Court, in the exercise of its adjudicative function, to declare the authority of the courts of this State to divert a criminal proceeding, after a hearing, without the consent of the prosecutor, in the light of the doctrine of separation of powers; (2) The power of the Supreme Court, in the exercise of its rule-making power, to declare the authority of the courts of this State to divert a criminal proceeding without the consent of the prosecutor; (3) In respect of both of the foregoing, whether there is any distinction between proceedings pos	1	1
Industrial Lessors, Inc. v. City of Garfieldgreen njsuperctappdiv · 1972 · cited in 1 New Jersey opinions naming this issue, 1973–1973 1 sentence 1973Industrial Lessors, Inc. v. Garfield, 119 N.J.	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (15)

Case	Cited	Years
Costello v. Ocean County Observer green nj · 1994 2 sentences 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)). 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)).	1	2012–2012
Hornberger v. American Broadcasting Cos., Inc. green njsuperctappdiv · 2002 2 sentences 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)). 2012Cos., 351 N.J.Super. 577, 598 , 799 A.2d 566 (App.Div.2002) (“actual malice standard applies to the false light claim to avoid violation of the First Amendment’s protection of freedom of expression”) (citing Hustler Magazine v. Falwell, 485 U.S. 46, 56 , 108 S.Ct. 876, 883 , 99 L.Ed.2d 41, 53 (1988)), and through proofs that are both clear and convincing, see Costello, supra, 136 N.J. at 614 , 643 A.2d 1012 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254-55 , 106 S.Ct. 2505, 2513 , 91 L.Ed.2d 202, 215-16 (1986)).	1	2012–2012
General Ceramics Inc. v. Firemen's Fund Insurance Companies green ca3 · 1995 1 sentence 1998We consider this record not only in the light of these factors but also in the light of Pfizer’s express approval of General Ceramics Inc. v. Firemen’s Fund Ins., 66 F.3d 647 (3d Cir.1995), and of this court’s adoption of the General Ceramics rationale in J.	1	1998–1998
J. JOSEPHSON v. Crum & Forster green njsuperctappdiv · 1996 2 sentences 1998Josephson v. Crum & Forster, 293 N.J.Super. 170 , 679 A.2d 1206 (App.Div.1996). 1998Josephson v. Crum & Forster, 293 N.J.Super. 170 , 679 A.2d 1206 (App.Div.1996).	1	1998–1998
Decker v. Princeton Packet, Inc. green nj · 1989 2 sentences 1997Steward’s proposed proofs in the light of the test set forth in Decker v. Princeton Packet, 116 N.J. 418 , 561 A.2d 1122 (1989). 1997Steward’s proposed proofs in the light of the test set forth in Decker v. Princeton Packet, 116 N.J. 418 , 561 A.2d 1122 (1989).	1	1997–1997
Matter of Adoption of a Child of Indian Heritage green nj · 1988 1 sentence 1991Therefore states may constitutionally deny an unwed father parental status unless and until he manifests an interest in developing a relationship with that child, provided that the qualifications for establishing such rights are not beyond the control of an interested putative father to satisfy____ Following the Court’s decision in Stanley [Stanley v. Illinois, 405 U.S. 645 , 92 S.Ct. 1208 , 31 L.Ed.2d 551 (1972) ] many states adopted statutes defining the circumstances under which a man would be presumed to be a child’s father and thus entitled to due process in any proceeding involving the c	1	1991–1991
Stanley v. Illinois green scotus · 1972 2 sentences 1991Therefore states may constitutionally deny an unwed father parental status unless and until he manifests an interest in developing a relationship with that child, provided that the qualifications for establishing such rights are not beyond the control of an interested putative father to satisfy____ Following the Court’s decision in Stanley [Stanley v. Illinois, 405 U.S. 645 , 92 S.Ct. 1208 , 31 L.Ed.2d 551 (1972) ] many states adopted statutes defining the circumstances under which a man would be presumed to be a child’s father and thus entitled to due process in any proceeding involving the c 1991Therefore states may constitutionally deny an unwed father parental status unless and until he manifests an interest in developing a relationship with that child, provided that the qualifications for establishing such rights are not beyond the control of an interested putative father to satisfy____ Following the Court’s decision in Stanley [Stanley v. Illinois, 405 U.S. 645 , 92 S.Ct. 1208 , 31 L.Ed.2d 551 (1972) ] many states adopted statutes defining the circumstances under which a man would be presumed to be a child’s father and thus entitled to due process in any proceeding involving the c	1	1991–1991
State v. Hines green njsuperctappdiv · 1970 1 sentence 1977State v. Hines, 109 N.J.	1	1977–1977
De Gray v. Murray green nj · 1903 1 sentence 1967In the light of the analysis we have made of the statute hereinafter it will make no difference whether or not we accept DeGray v. Murray, supra , as authoritative of the law of this State when the 1933 statute was adopted.	1	1967–1967
State v. Barts green nj · 1945 1 sentence 1958The action of the trial judge was entirely proper, and he certainly did not abuse his discretion, State v. Barts, 132 N.J.L. 74 ( Sup. Ct. 1944), affirmed Ibid., 132 N.J.L. 420 ( E. & A. 1945), particularly in the light of defense counsel's unequivocal consent.	1	1958–1958
State v. Barts green nj · 1944 1 sentence 1958The action of the trial judge was entirely proper, and he certainly did not abuse his discretion, State v. Barts, 132 N.J.L. 74 ( Sup. Ct. 1944), affirmed Ibid., 132 N.J.L. 420 ( E. & A. 1945), particularly in the light of defense counsel's unequivocal consent.	1	1958–1958
Stuyvesant Town, Inc. v. Ligham green nj · 1955 1 sentence 1956The provisions of the ordinance in the main are patterned after the provisions of the state rent control statute in its delegation of power to the State Rent Control Director, and the decisions sustaining their sufficiency seem to me to be decisive here, Jamouneau v. Harner, supra ( 16 N.J. 500 ); Stuyvesant Town, Inc., v. Ligham, supra ( 17 N.J. 473 ), especially so in the light of the rule of reasonableness which confines the exercise of municipal power and the judicial superintendence thereof.	1	1956–1956
Jamouneau v. Harner green nj · 1954 2 sentences 1956The provisions of the ordinance in the main are patterned after the provisions of the state rent control statute in its delegation of power to the State Rent Control Director, and the decisions sustaining their sufficiency seem to me to be decisive here, Jamouneau v. Harner, supra ( 16 N.J. 500 ); Stuyvesant Town, Inc., v. Ligham, supra ( 17 N.J. 473 ), especially so in the light of the rule of reasonableness which confines the exercise of municipal power and the judicial superintendence thereof. 1956The provisions of the ordinance in the main are patterned after the provisions of the state rent control statute in its delegation of power to the State Rent Control Director, and the decisions sustaining their sufficiency seem to me to be decisive here, Jamouneau v. Harner, supra ( 16 N.J. 500 ); Stuyvesant Town, Inc., v. Ligham, supra ( 17 N.J. 473 ), especially so in the light of the rule of reasonableness which confines the exercise of municipal power and the judicial superintendence thereof.	1	1956–1956
Hansen v. Eagle-Picher Lead Co. green nj · 1951 1 sentence 1952The merit of this argument must be assayed in the light of the principle set forth in Hansen v. Eagle-Picher Lead Co., 8 N.J. 133 , 84 A. 2 d 281 ( Sup. Ct. 1951).	1	1952–1952
Solomon v. Finer green nj · 1935 1 sentence 1949The universal rule is that where a person is injured through the alleged negligence of another person, it is not necessary for the defendant to offer testimony of the plaintiff's failure to exercise reasonable care, but, as was said in Solomon v. Finer, 115 N.J.L. 404 ( Sup. Ct. 1935), "The test is whether an ordinarily prudent person would, under the same or similar circumstances, have incurred the risk which such conduct involved; and where reasonably careful men might differ in the appraisement of the conduct, in the light of this principle, the question is one for the trier of the facts."	1	1949–1949

Where else courts name it

CA 181 (1892–2026) NY 87 (1872–2021) TX 75 (1911–2024) IL 62 (1880–2026) PA 53 (1907–2025) NE 42 (1887–2022) FL 32 (1915–2009) NC 32 (1899–2026) MI 30 (1914–2022) AL 28 (1909–2013) MO 27 (1898–2008) OR 26 (1893–2014) LA 25 (1937–2016) TN 23 (1956–2022) GA 21 (1902–2025) NJ 20 (1949–2026) MA 20 (1857–2007) OK 19 (1907–2020) IA 18 (1872–2018) CT 18 (1921–2017) SC 15 (1940–1975) IN 15 (1864–2015) NV 15 (1914–2017) KY 14 (1908–2026) MD 14 (1928–2022) SD 13 (1922–2009) WA 12 (1911–2020) NM 12 (1941–2018) ID 12 (1912–2001) OH 12 (1918–2023) AZ 11 (1966–2026) UT 10 (1955–2025) KS 10 (1896–1989) ME 8 (1975–2012) WI 7 (1900–1988) MN 7 (1906–1965) CO 7 (1894–1973) MS 6 (1916–2004) HI 5 (1963–2022) MT 5 (1910–1938) ND 5 (1905–1952) WY 5 (1923–1991) RI 4 (1962–1983) DE 4 (1961–1964) AR 4 (1934–1977) DC 4 (1943–1985) WV 3 (1959–2013) VA 3 (1909–2008) NH 2 (1975–1981) PR 2 (1929–1937) VT 2 (1962–2024)

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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