constructive discharge claim (New Jersey) · Go Syfert
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constructive discharge claim in New Jersey

19 New Jersey opinions name it 2 courts 2001–2025 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 (18)

CaseFollowedCited
Shepherd v. Hunterdon Dev. Ctr.green
njsuperctappdiv · 2001 · cited in 3 New Jersey opinions naming this issue, 2017–2024
2 sentences

2024Ctr., 336 N.J.

2024Ibid. (quoting Shepherd v. Hunterdon Developmental Ctr., 336 N.J.

33
Jones v. Aluminum Shapes, Inc.green
njsuperctappdiv · 2001 · cited in 9 New Jersey opinions naming this issue, 2005–2025
2 sentences

2025In contrast, a constructive discharge claim has a higher standard and requires "not merely 'severe or pervasive' conduct, but conduct that is so intolerable that a reasonable person would be forced to resign rather than continue to endure it." Ibid. (citing Jones v. Aluminum Shapes, Inc., 339 N.J.

2025By contrast, a constructive discharge claim has a higher standard and requires "not merely 'severe or pervasive' conduct, but conduct that is so intolerable that a reasonable person would be forced to resign rather than continue to endure it." Ibid. (citing Jones v. Aluminum Shapes, Inc., 339 N.J.

29
Shepherd v. Hunterdon Developmental Centergreen
nj · 2002 · cited in 8 New Jersey opinions naming this issue, 2002–2025
2 sentences

2025In contrast, a constructive discharge claim has a higher standard and requires "not merely 'severe or pervasive' conduct, but conduct that is so intolerable that a reasonable person would be forced to resign rather than continue to endure it." Ibid. (citing Jones v. Aluminum Shapes, Inc., 339 N.J.

2025By contrast, a constructive discharge claim has a higher standard and requires "not merely 'severe or pervasive' conduct, but conduct that is so intolerable that a reasonable person would be forced to resign rather than continue to endure it." Ibid. (citing Jones v. Aluminum Shapes, Inc., 339 N.J.

28
Woods-Pirozzi v. Nabisco Foodsgreen
njsuperctappdiv · 1996 · cited in 2 New Jersey opinions naming this issue, 2001–2010
2 sentences

2010See T.L. v. Toys `R' Us, Inc., 255 N.J.Super. 616, 662 , 605 A. 2d 1125 (App.Div. 1992) [7] (observing that "an employee who has taken the initiative in terminating his or her employment will be awarded back pay only if he or she can show that the employer's discriminatory conduct has resulted in a `constructive discharge.'" (emphasis added)); see also Woods-Pirozzi v. Nabisco Foods, 290 N.J.Super. 252, 277 , 675 A. 2d 684 (App.Div.1996) (noting that once the trial court properly dismissed the plaintiff's constructive discharge claim, the dismissal of the claims for back pay and front pay was

2010See T.L. v. Toys `R' Us, Inc., 255 N.J.Super. 616, 662 , 605 A. 2d 1125 (App.Div. 1992) [7] (observing that "an employee who has taken the initiative in terminating his or her employment will be awarded back pay only if he or she can show that the employer's discriminatory conduct has resulted in a `constructive discharge.'" (emphasis added)); see also Woods-Pirozzi v. Nabisco Foods, 290 N.J.Super. 252, 277 , 675 A. 2d 684 (App.Div.1996) (noting that once the trial court properly dismissed the plaintiff's constructive discharge claim, the dismissal of the claims for back pay and front pay was

12
Donelson v. DuPont Chambers Worksgreen
nj · 2011 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025A-2855-23 21 Under CEPA, a "'[r]etaliatory action' is defined as 'the discharge, suspension or demotion of an employee, or other adverse employment action taken against an employee in the terms and conditions of employment.'" Donelson v. DuPont Chambers Works, 206 N.J. 243, 257 (2011) (quoting N.J.S.A. 34:19-2(e)).

11
Lynch v. Galler Seven-Up Pre-Mix Corp.green
nj · 1977 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025Defendants counter that plaintiff could not present a new theory during trial, which is "at variance" with pretrial discovery and evidence presented at trial, citing Lynch v. Galler Seven-Up Pre-Mix Corp., 74 N.J. 146, 151 (1977).

11
Toto v. PRINCETON TP.green
njsuperctappdiv · 2009 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019"A constructive discharge claim arises when an employee leaves the workplace because the 'employer knowingly permit[s] conditions of discrimination in employment so intolerable that a reasonable person subject to them would resign.'" Toto v. Princeton Township, 404 N.J.

11
TL v. ToysR'Us, Inc.green
njsuperctappdiv · 1992 · cited in 1 New Jersey opinions naming this issue, 2010–2010
2 sentences

2010See T.L. v. Toys `R' Us, Inc., 255 N.J.Super. 616, 662 , 605 A. 2d 1125 (App.Div. 1992) [7] (observing that "an employee who has taken the initiative in terminating his or her employment will be awarded back pay only if he or she can show that the employer's discriminatory conduct has resulted in a `constructive discharge.'" (emphasis added)); see also Woods-Pirozzi v. Nabisco Foods, 290 N.J.Super. 252, 277 , 675 A. 2d 684 (App.Div.1996) (noting that once the trial court properly dismissed the plaintiff's constructive discharge claim, the dismissal of the claims for back pay and front pay was

2010See T.L. v. Toys `R' Us, Inc., 255 N.J.Super. 616, 662 , 605 A. 2d 1125 (App.Div. 1992) [7] (observing that "an employee who has taken the initiative in terminating his or her employment will be awarded back pay only if he or she can show that the employer's discriminatory conduct has resulted in a `constructive discharge.'" (emphasis added)); see also Woods-Pirozzi v. Nabisco Foods, 290 N.J.Super. 252, 277 , 675 A. 2d 684 (App.Div.1996) (noting that once the trial court properly dismissed the plaintiff's constructive discharge claim, the dismissal of the claims for back pay and front pay was

11
Kolb v. Burnsgreen
njsuperctappdiv · 1999 · cited in 1 New Jersey opinions naming this issue, 2005–2005
2 sentences

2005See Kolb v. Burns, 320 N.J.Super. 467, 477 , 727 A. 2d 525 (App.Div.1999) ("[B]ecause CEPA is anti-discrimination legislation, the elements of a cause of action under the Act are derived from the Civil Rights landscape."); see also Green v. Jersey City Bd. of Educ., 177 N.J. 434, 448 , 828 A. 2d 883 (2003).

2005See Kolb v. Burns, 320 N.J.Super. 467, 477 , 727 A. 2d 525 (App.Div.1999) ("[B]ecause CEPA is anti-discrimination legislation, the elements of a cause of action under the Act are derived from the Civil Rights landscape."); see also Green v. Jersey City Bd. of Educ., 177 N.J. 434, 448 , 828 A. 2d 883 (2003).

11
Green v. Jersey City Board of Educationgreen
nj · 2003 · cited in 1 New Jersey opinions naming this issue, 2005–2005
2 sentences

2005See Kolb v. Burns, 320 N.J.Super. 467, 477 , 727 A. 2d 525 (App.Div.1999) ("[B]ecause CEPA is anti-discrimination legislation, the elements of a cause of action under the Act are derived from the Civil Rights landscape."); see also Green v. Jersey City Bd. of Educ., 177 N.J. 434, 448 , 828 A. 2d 883 (2003).

2005See Kolb v. Burns, 320 N.J.Super. 467, 477 , 727 A. 2d 525 (App.Div.1999) ("[B]ecause CEPA is anti-discrimination legislation, the elements of a cause of action under the Act are derived from the Civil Rights landscape."); see also Green v. Jersey City Bd. of Educ., 177 N.J. 434, 448 , 828 A. 2d 883 (2003).

11
Farina v. Compuware Corp.green
azd · 2003 · cited in 1 New Jersey opinions naming this issue, 2004–2004
1 sentence

2004Farina v. Compuware Corp., 256 F.Supp. 2d 1033, 1051-52 (D.Ariz.2003) (summary judgment denied on retaliation claim where plaintiff was terminated after letter considering herself constructively discharged; plaintiff made a prima facie case that she was terminated due to retaliation for her EEOC complaint and to avoid a constructive discharge claim).

11
Delashmutt v. Wis-Pak Plastics, Inc.green
iand · 1998 · cited in 1 New Jersey opinions naming this issue, 2004–2004
1 sentence

2004See also Delashmutt v. Wis-Pak Plastics, Inc., 990 F.Supp. 689, 696, 703 (N.D.Ia.1998)(holding that plaintiff's claims of both constructive discharge and retaliation survived summary judgment because there were genuine material issues of fact as to retaliation for complaint of sexual harassment and claim that changed working conditions after filing of harassment complaint would result in resignation).

11
Woods v. Delta Beverage Group, Inc.green
ca5 · 2001 · cited in 1 New Jersey opinions naming this issue, 2002–2002
2 sentences

2002See, e.g., EEOC v. Univ. of Chicago Hosps., 276 F.3d 326, 331-32 (7th Cir.2002) (observing that to establish constructive discharge under Title VII plaintiff is required “to demonstrate a discriminary work environment even more egregious than the high standard for hostile work environment”) (internal quotation marks and citation omitted); Woods v. Delta Beverage Group, Inc., 274 F.3d 295, 301 (5th Cir.2001) (observing that to establish constructive discharge claim under Title VII plaintiff “must demonstrate a greater severity or pervasiveness of harassment than the minimum required to prove a

2002See, e.g., EEOC v. Univ. of Chicago Hosps., 276 F. 3d 326, 331-32 (7th Cir.2002) (observing that to establish constructive discharge under Title VII plaintiff is required "to demonstrate a discriminary work environment even more egregious than the high standard for hostile work environment") (internal quotation marks and citation omitted); Woods v. Delta Beverage Group, Inc., 274 F. 3d 295, 301 (5th Cir.2001) (observing that to establish constructive discharge claim under Title VII plaintiff "must demonstrate a greater severity or pervasiveness of harassment than the minimum required to prove

11
Equal Employment Opportunity Commission v. University of Chicago Hospitalsgreen
ca7 · 2002 · cited in 1 New Jersey opinions naming this issue, 2002–2002
2 sentences

2002See, e.g., EEOC v. Univ. of Chicago Hosps., 276 F.3d 326, 331-32 (7th Cir.2002) (observing that to establish constructive discharge under Title VII plaintiff is required “to demonstrate a discriminary work environment even more egregious than the high standard for hostile work environment”) (internal quotation marks and citation omitted); Woods v. Delta Beverage Group, Inc., 274 F.3d 295, 301 (5th Cir.2001) (observing that to establish constructive discharge claim under Title VII plaintiff “must demonstrate a greater severity or pervasiveness of harassment than the minimum required to prove a

2002See, e.g., EEOC v. Univ. of Chicago Hosps., 276 F. 3d 326, 331-32 (7th Cir.2002) (observing that to establish constructive discharge under Title VII plaintiff is required "to demonstrate a discriminary work environment even more egregious than the high standard for hostile work environment") (internal quotation marks and citation omitted); Woods v. Delta Beverage Group, Inc., 274 F. 3d 295, 301 (5th Cir.2001) (observing that to establish constructive discharge claim under Title VII plaintiff "must demonstrate a greater severity or pervasiveness of harassment than the minimum required to prove

11
Lowell v. Glidden-Durkee, Div. of SCM Corp.green
ilnd · 1981 · cited in 1 New Jersey opinions naming this issue, 2001–2001
1 sentence

2001See, e.g., Maluo v. Nakano, 125 F.Supp. 2d 1224, 1236 (D.Haw.2000) (holding that under Hawaii law, the period of limitations for a constructive discharge claim begins to run on the date of employee's resignation); Lowell v. Glidden-Durkee, 529 F.Supp. 17, 23 (N.D.Ill.1981) (ruling that limitations period was triggered on the date plaintiff tendered her resignation rather than the resignation's effective date); Hancock v. Bureau of Nat'l Affairs, Inc., 645 A. 2d 588, 590 (D.C.1994) (holding that limitations period began at point when plaintiff gave retirement notice because "[a]ny discriminator

11
Maluo v. Nakanogreen
hid · 2000 · cited in 1 New Jersey opinions naming this issue, 2001–2001
1 sentence

2001See, e.g., Maluo v. Nakano, 125 F.Supp. 2d 1224, 1236 (D.Haw.2000) (holding that under Hawaii law, the period of limitations for a constructive discharge claim begins to run on the date of employee's resignation); Lowell v. Glidden-Durkee, 529 F.Supp. 17, 23 (N.D.Ill.1981) (ruling that limitations period was triggered on the date plaintiff tendered her resignation rather than the resignation's effective date); Hancock v. Bureau of Nat'l Affairs, Inc., 645 A. 2d 588, 590 (D.C.1994) (holding that limitations period began at point when plaintiff gave retirement notice because "[a]ny discriminator

11
Jacobson v. Parda Federal Credit Uniongreen
mich · 1998 · cited in 1 New Jersey opinions naming this issue, 2001–2001
2 sentences

2001Credit Union, 457 Mich. 318 , 577 N.W. 2d 881, 885 (1998) (holding that statute of limitations under Michigan's whistleblower statute commenced on date of resignation); University of Texas Med.

2001Credit Union, 457 Mich. 318 , 577 N.W. 2d 881, 885 (1998) (holding that statute of limitations under Michigan's whistleblower statute commenced on date of resignation); University of Texas Med.

11
Hancock v. Bureau of National Affairs, Inc.green
dc · 1994 · cited in 1 New Jersey opinions naming this issue, 2001–2001
1 sentence

2001See, e.g., Maluo v. Nakano, 125 F.Supp. 2d 1224, 1236 (D.Haw.2000) (holding that under Hawaii law, the period of limitations for a constructive discharge claim begins to run on the date of employee's resignation); Lowell v. Glidden-Durkee, 529 F.Supp. 17, 23 (N.D.Ill.1981) (ruling that limitations period was triggered on the date plaintiff tendered her resignation rather than the resignation's effective date); Hancock v. Bureau of Nat'l Affairs, Inc., 645 A. 2d 588, 590 (D.C.1994) (holding that limitations period began at point when plaintiff gave retirement notice because "[a]ny discriminator

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Carol Aman Jeanette Johnson v. Cort Furniture Rental Corporationgreen
ca3 · 1996 · cited in 1 New Jersey opinions naming this issue, 2001–2001
2 sentences

2001But see Aman v. Cort Furniture Rental Corp., 85 F. 3d 1074 (3d Cir. 1996).

2001Id. at 1084 .

11

Also cited on this issue (3)

CaseCitedYears
Nicholas v. Mynster green
nj · 2013
1 sentence

2016Further, the Supreme Court in Shepherd made clear "a constructive discharge claim requires more egregious conduct than that sufficient for a hostile work environment claim." Ibid. 19 A-3691-14T3 produced evidence that the general manager had reprimanded her about talking with her co-workers about the incident with the customer.

12016–2016
Padilla v. BERKELEY EDUCATIONAL SERV. green
njsuperctappdiv · 2005
2 sentences

2010Id. at 184 , 891 A. 2d 616 .

2010Id. at 184 , 891 A. 2d 616 .

12010–2010
Muench v. Township of Haddon green
njsuperctappdiv · 1992
2 sentences

2009A constructive discharge claim arises when an employee leaves the workplace because the "`employer knowingly permit[s] conditions of discrimination in employment so intolerable that a reasonable person subject to them would resign.'" Shepherd v. Hunterdon Developmental Ctr., supra, 174 N.J. at 27-28 , 803 A. 2d 611 (alteration in original) (quoting Muench v. Twp. of Haddon, 255 N.J.Super. 288, 302 , 605 A. 2d 242 (App.Div.1992)).

2009A constructive discharge claim arises when an employee leaves the workplace because the "`employer knowingly permit[s] conditions of discrimination in employment so intolerable that a reasonable person subject to them would resign.'" Shepherd v. Hunterdon Developmental Ctr., supra, 174 N.J. at 27-28 , 803 A. 2d 611 (alteration in original) (quoting Muench v. Twp. of Haddon, 255 N.J.Super. 288, 302 , 605 A. 2d 242 (App.Div.1992)).

12009–2009

Statutes the citing opinions construe

NJ § N.J. Stat. § 10:5-1 (9) NJ § N.J. Stat. § 10:5-12 (6)

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

TX 22 (1991–2025) CA 22 (1994–2025) NJ 19 (2001–2025) OH 18 (2000–2025) WA 14 (1985–2023) PA 9 (2001–2023) WI 9 (1993–2023) CT 7 (1998–2020) TN 6 (1996–2021) IN 6 (1983–2009) NY 6 (1985–2021) MA 5 (1996–2006) IA 5 (1997–2022) MN 5 (1991–2024) WV 4 (1992–2010) ME 4 (2001–2025) NH 4 (2012–2019) DE 3 (2015–2025) AK 3 (2000–2025) OR 3 (1995–2018) VA 3 (1998–2008) ID 3 (2009–2013) AZ 2 (2006–2018) DC 2 (1986–2014) FL 2 (2001–2004) MO 2 (2009–2024) VI 2 (2015–2015) WY 2 (1996–1996) MT 2 (1991–2023) MI 2 (1993–1998) LA 2 (2003–2006)

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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