privity requirement (New Jersey) · Go Syfert
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privity requirement in New Jersey

20 New Jersey opinions name it 2 courts 1971–2025 2 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 (5)

CaseFollowedCited
Banco Popular North America v. Gandigreen
nj · 2005 · cited in 6 New Jersey opinions naming this issue, 2013–2025
2 sentences

2025Contrariwise, if the attorney does absolutely nothing to induce reasonable reliance by a third party, there is no relationship to substitute for the privity requirement. [Gandi, 184 N.J. at 180 .] Here, we are convinced that Isolda's representation of Abrams's father, in a lawsuit between Abrams and his father, could not have induced a reasonable reliance in Isolda or created a "relationship to substitute for the privity requirement." Ibid.

2025Contrariwise, if the attorney does absolutely nothing to induce reasonable reliance by a third party, there is no relationship to substitute for the privity requirement. [Gandi, 184 N.J. at 180 .] Here, we are convinced that Isolda's representation of Abrams's father, in a lawsuit between Abrams and his father, could not have induced a reasonable reliance in Isolda or created a "relationship to substitute for the privity requirement." Ibid.

36
Kaufman v. I-Stat Corp.green
nj · 2000 · cited in 1 New Jersey opinions naming this issue, 2024–2024
1 sentence

2024See Banco Popular, 184 N.J. at 182 (holding that bank could not establish negligent misrepresentation claim against attorney absent a "relationship . . . that substitute[s] for the privity requirement"); Kaufman v. i-Stat Corp., 165 N.J. 94, 109 (2000) ("The element of reliance is the same for fraud and negligent misrepresentation.").

11
Aronsohn v. Mandaragreen
nj · 1984 · cited in 1 New Jersey opinions naming this issue, 1985–1985
1 sentence

1985See Aronsohn, supra. Nevertheless, under the circumstances of this case, the privity requirement as a bar to a cause of action may have been somewhat exaggerated or magnified.

11
Thompson Farms v. CORNO FEED PRODUCTS, ETC.green
indctapp · 1977 · cited in 1 New Jersey opinions naming this issue, 1985–1985
2 sentences

1985See Thompson Farms v. Corno Feed Products, 173 Ind.App. 682 , 366 N.E. 2d 3 (1977) (court allowed recovery on implied warranty notwithstanding lack of privity when the intermediate seller was shown to be an agent of manufacturer and the buyer had seen advertisements of the product exhibited by the agent).

1985See Thompson Farms v. Corno Feed Products, 173 Ind.App. 682 , 366 N.E. 2d 3 (1977) (court allowed recovery on implied warranty notwithstanding lack of privity when the intermediate seller was shown to be an agent of manufacturer and the buyer had seen advertisements of the product exhibited by the agent).

11
Miller v. Muscarellegreen
njsuperctappdiv · 1961 · cited in 1 New Jersey opinions naming this issue, 1985–1985
1 sentence

1985The misfeasance-nonfeasance distinction has been subject to criticism in this State as being "little more than a totally illogical remnant of the privity doctrine." Miller v. Muscarelle, 67 N.J.

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 (13)

CaseCitedYears
Henningsen v. Bloomfield Motors, Inc. green
nj · 1960
2 sentences

1999An early, but important, example is Henningsen v. Bloomfield Motors Inc., [ 32 N.J. 358 , 161 A.2d 69 (1960) ] the seminal case marking “the date of the fall of the citadel of privity,” in which the Court recognized the “advent of large scale advertising by manufacturers” as a basis for reconsidering the long-standing privity rule in warranty cases.

1999An early, but important, example is Henningsen v. Bloomfield Motors Inc., [ 32 N.J. 358 , 161 A.2d 69 (1960) ] the seminal case marking “the date of the fall of the citadel of privity,” in which the Court recognized the “advent of large scale advertising by manufacturers” as a basis for reconsidering the long-standing privity rule in warranty cases.

21999–2009
Petrillo v. Bachenberg green
nj · 1995
2 sentences

2005Indeed, in Petrillo , we noted that “when courts relax the privity requirement, they typically limit a lawyers duty to situations in which the lawyer intended or should have foreseen that the third party would rely on the lawyers work.” Id. at 482 , 655 A.2d 1354 (citing Jay M. *181 Feinman, Economic Negligence: Liability of Professionals and Businesses to Third Parties for Economic Loss 131-34 (1995)).

2000In reaching that conclusion, the Court noted that “when courts relax the privity requirement, they typically limit a lawyer’s duty to situations in which the lawyer intended or should have foreseen that the third-party would rely on the lawyer’s work.” 139 N.J. at 482 , 655 A.2d 1354 .

22000–2005
H. Rosenblum, Inc. v. Adler green
nj · 1983
2 sentences

1995In reversing the trial court's dismissal of that claim, the Court extended its prior decision in Rosenblum v. Adler, 93 N.J. 324 , 461 A. 2d 138 (1983) which relaxed the privity requirement in a case involving an accounting firms's negligent audit of a corporation's financial statements upon which stock purchasers had relied.

1995In reversing the trial court's dismissal of that claim, the Court extended its prior decision in Rosenblum v. Adler, 93 N.J. 324 , 461 A. 2d 138 (1983) which relaxed the privity requirement in a case involving an accounting firms's negligent audit of a corporation's financial statements upon which stock purchasers had relied.

21993–1995
Gold Mills, Inc. v. Orbit Processing Corp. green
njsuperctappdiv · 1972
2 sentences

1993Id. at 376 , 297 A. 2d 203 .

1985Citing Miller's rejection of the misfeasance-nonfeasance distinction, he held that since "the privity rule is no longer viable in the area of tort liability there is no reason why a contractor should not have the same duties toward a stranger to the contract as any member of society to another, i.e., to exercise due care to avoid injury to another's person or property." Id. at 376 .

21985–1993
Keyes v. Guy Bailey Homes, Inc. green
miss · 1983
1 sentence

1984The builder always has available the defense that the defects are not attributable to him. [ 439 So.2d at 672 .] We agree with the Mississippi Supreme Court that the privity requirement should be abandoned in suits brought by a homeowner against a contractor for violation of an implied promise of good workmanship.

11984–1984
Landell v. Lybrand green
pa · 1919
2 sentences

1983The earliest decision in the United States our research has uncovered is Landell v. Lybrand, 264 Pa. 406 , 107 A. 783 (1919), holding that an accountant was not liable for misstatements in a company’s financial statements to a third person who had relied upon the financials and had purchased the company’s stock.

1983The earliest decision in the United States our research has uncovered is Landell v. Lybrand, 264 Pa. 406 , 107 A. 783 (1919), holding that an accountant was not liable for misstatements in a company’s financial statements to a third person who had relied upon the financials and had purchased the company’s stock.

11983–1983
Stephens Industries, Inc., and Morris Stephens v. Haskins and Sells, Axel Ahlberg, Jack Crane and Arlo M. Hall green
ca10 · 1971
1 sentence

1982While some courts have continued to uphold this strict privity defense, e.g., Stephens Industries, Inc. v. Haskins & Sells, 438 F. 2d 357 (10 Cir.1971), most cases decided since then have advanced somewhat beyond that restrictive approach.

11982–1982
White v. Guarente green
ny · 1977
2 sentences

1982White v. Guarente, 43 N.Y. 2d 356 , 401 N.Y.S. 2d 474 , 372 N.E. 2d 315 (Ct.App. 1977).

1982White v. Guarente, 43 N.Y. 2d 356 , 401 N.Y.S. 2d 474 , 372 N.E. 2d 315 (Ct.App. 1977).

11982–1982
Miller v. Davis and Averill, Inc. green
nj · 1948
1 sentence

1980In Totten v. Gruzen, 52 N.J. 202 (1968), the court established that architects and engineers may be held liable for personal injuries to third persons in the absence of privity and overruled the "completed *343 and accepted" rule of Miller v. Davis & Averill, Inc., 137 N.J.L. 671 (E. & A. 1948).

11980–1980
United States v. Rogers & Rogers green
casd · 1958
1 sentence

1980In United States v. Rogers and Rogers, 161 F. Supp. 132 (S.D.Cal. 1958), an architect was sued by a contractor who had sustained economic damages.

11980–1980
MacPherson v. . Buick Motor Co. green
ny · 1916
2 sentences

1980Law 385 (E. & A. 1925), following MacPherson v. Buick Motor Co., 217 N.Y. 382 , 111 N.E. 1050 (Ct.App. 1916), and continued with Totten .

1980Law 385 (E. & A. 1925), following MacPherson v. Buick Motor Co., 217 N.Y. 382 , 111 N.E. 1050 (Ct.App. 1916), and continued with Totten .

11980–1980
Totten v. GRUZEN green
nj · 1968
1 sentence

1980In Totten v. Gruzen, 52 N.J. 202 (1968), the court established that architects and engineers may be held liable for personal injuries to third persons in the absence of privity and overruled the "completed *343 and accepted" rule of Miller v. Davis & Averill, Inc., 137 N.J.L. 671 (E. & A. 1948).

11980–1980
Caullett v. Stanley Stilwell & Sons, Inc. green
njsuperctappdiv · 1961
1 sentence

1971Likewise, our courts have "consistently enforced the covenantal rights of an owner of benefited property against a successor, with notice, to the burdened land, even though the covenant did not run with the land at law." Caullett v. Stanley Stilwell & Sons, Inc., supra, 67 N.J.

11971–1971

Where else courts name it

NY 60 (1926–2024) IL 53 (1962–2026) CA 52 (1958–2026) FL 38 (1958–2021) IN 33 (1980–2026) TX 32 (1965–2023) GA 28 (1939–2019) PA 26 (1960–2023) OH 24 (1988–2022) NC 23 (1916–2026) VA 23 (1979–2016) MI 22 (1969–2026) WA 21 (1955–2015) IA 20 (1973–2021) NJ 20 (1971–2025) MD 19 (1984–2024) CT 18 (1960–2025) RI 14 (1965–2010) AR 14 (1994–2021) MO 13 (1952–2024) AZ 12 (1969–2017) VT 12 (1984–2024) NH 10 (1982–2020) DE 9 (1970–2018) MN 9 (1991–2018) SC 9 (2000–2019) MS 9 (1987–2014) DC 8 (1989–2022) WV 7 (1964–2010) ME 7 (1928–2020) ID 7 (1985–2018) CO 7 (1972–2020) UT 6 (1989–2008) AK 6 (1970–2021) NV 6 (2009–2020) KS 6 (1967–2022) SD 6 (1936–2022) WI 5 (1973–2019) KY 5 (1962–2026) MA 5 (1977–2007) WY 5 (1980–2004) LA 5 (1958–1992) OR 4 (1976–1999) MT 4 (1984–2010) AL 4 (1924–2024) ND 4 (1965–2020) NM 3 (1972–2004) OK 3 (1974–2025) TN 2 (1969–2026) HI 2 (1997–2001)

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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