correction error (New Jersey) · Go Syfert
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correction error in New Jersey

14 New Jersey opinions name it 3 courts 1951–2013 0 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 (7)

CaseFollowedCited
Lockwood v. Walshgreen
njsuperctappdiv · 1946 · cited in 3 New Jersey opinions naming this issue, 1999–2013
2 sentences

2013Rather, given the administrative histoiy of [Taxation’s] earlier determination (communicated to the taxpayer) that the taxpayer was not entitled to a refund because of the statute of limitations, the recovery of the funds here is more akin to the correction of a clerical error that led to the mailing of a tax refund check to which the taxpayer was not entitled, rather than the correction of an error in judgment. [Playmates Toys, supra, 162 N.J. at 187 , 742 A.2d 968 ] The Court relied upon Lockwood v. Walsh, 137 N.J.

2013Eq. 445, 450 , 45 A.2d 305 (Prerog.Ct.1946) for its conclusion.

23
Manczak v. Township of Dovergreen
njtaxct · 1981 · cited in 3 New Jersey opinions naming this issue, 1981–1994
2 sentences

1994Village, supra, 8 N.J.Tax at 304 (declaring that N.J.S.A 54:51A-7 potentially “does violence to the concept of finality of assessments necessary for the predictability of revenues and the orderly financing of government”); Flint, supra, 6 N.J.Tax at 108 (“[T]he extraordinary remedy of [the Correction of Errors Statute] might quickly become a standard method of review for any taxpayer who could find a factual error on his property record card even several years after his normal appeal time has expired.”); Springfield, supra, 3 N.J.Tax at 95 (“To permit plaintiff to rectify its omission by means

1994Village, supra, 8 N.J.Tax at 304 (declaring that N.J.S.A 54:51A-7 potentially “does violence to the concept of finality of assessments necessary for the predictability of revenues and the orderly financing of government”); Flint, supra, 6 N.J.Tax at 108 (“[T]he extraordinary remedy of [the Correction of Errors Statute] might quickly become a standard method of review for any taxpayer who could find a factual error on his property record card even several years after his normal appeal time has expired.”); Springfield, supra, 3 N.J.Tax at 95 (“To permit plaintiff to rectify its omission by means

13
Playmates Toys Inc. v. Director, Division of Taxationgreen
nj · 1999 · cited in 2 New Jersey opinions naming this issue, 2002–2013
2 sentences

2013Rather, given the administrative histoiy of [Taxation’s] earlier determination (communicated to the taxpayer) that the taxpayer was not entitled to a refund because of the statute of limitations, the recovery of the funds here is more akin to the correction of a clerical error that led to the mailing of a tax refund check to which the taxpayer was not entitled, rather than the correction of an error in judgment. [Playmates Toys, supra, 162 N.J. at 187 , 742 A.2d 968 ] The Court relied upon Lockwood v. Walsh, 137 N.J.

2013Rather, given the administrative histoiy of [Taxation’s] earlier determination (communicated to the taxpayer) that the taxpayer was not entitled to a refund because of the statute of limitations, the recovery of the funds here is more akin to the correction of a clerical error that led to the mailing of a tax refund check to which the taxpayer was not entitled, rather than the correction of an error in judgment. [Playmates Toys, supra, 162 N.J. at 187 , 742 A.2d 968 ] The Court relied upon Lockwood v. Walsh, 137 N.J.

12
L.S. Village, Inc. v. Lawrence Townshipgreen
njsuper · 1985 · cited in 1 New Jersey opinions naming this issue, 1994–1994
1 sentence

1994Village, supra, 8 N.J.Tax at 304 (declaring that N.J.S.A 54:51A-7 potentially “does violence to the concept of finality of assessments necessary for the predictability of revenues and the orderly financing of government”); Flint, supra, 6 N.J.Tax at 108 (“[T]he extraordinary remedy of [the Correction of Errors Statute] might quickly become a standard method of review for any taxpayer who could find a factual error on his property record card even several years after his normal appeal time has expired.”); Springfield, supra, 3 N.J.Tax at 95 (“To permit plaintiff to rectify its omission by means

11
Township of Springfield v. Garnergreen
njtaxct · 1981 · cited in 1 New Jersey opinions naming this issue, 1994–1994
2 sentences

1994Village, supra, 8 N.J.Tax at 304 (declaring that N.J.S.A 54:51A-7 potentially “does violence to the concept of finality of assessments necessary for the predictability of revenues and the orderly financing of government”); Flint, supra, 6 N.J.Tax at 108 (“[T]he extraordinary remedy of [the Correction of Errors Statute] might quickly become a standard method of review for any taxpayer who could find a factual error on his property record card even several years after his normal appeal time has expired.”); Springfield, supra, 3 N.J.Tax at 95 (“To permit plaintiff to rectify its omission by means

1994Village, supra, 8 N.J.Tax at 304 (declaring that N.J.S.A 54:51A-7 potentially “does violence to the concept of finality of assessments necessary for the predictability of revenues and the orderly financing of government”); Flint, supra, 6 N.J.Tax at 108 (“[T]he extraordinary remedy of [the Correction of Errors Statute] might quickly become a standard method of review for any taxpayer who could find a factual error on his property record card even several years after his normal appeal time has expired.”); Springfield, supra, 3 N.J.Tax at 95 (“To permit plaintiff to rectify its omission by means

11
Flint v. Lawrence Townshipgreen
njtaxct · 1983 · cited in 1 New Jersey opinions naming this issue, 1994–1994
2 sentences

1994Village, supra, 8 N.J.Tax at 304 (declaring that N.J.S.A 54:51A-7 potentially “does violence to the concept of finality of assessments necessary for the predictability of revenues and the orderly financing of government”); Flint, supra, 6 N.J.Tax at 108 (“[T]he extraordinary remedy of [the Correction of Errors Statute] might quickly become a standard method of review for any taxpayer who could find a factual error on his property record card even several years after his normal appeal time has expired.”); Springfield, supra, 3 N.J.Tax at 95 (“To permit plaintiff to rectify its omission by means

1994Village, supra, 8 N.J.Tax at 304 (declaring that N.J.S.A 54:51A-7 potentially “does violence to the concept of finality of assessments necessary for the predictability of revenues and the orderly financing of government”); Flint, supra, 6 N.J.Tax at 108 (“[T]he extraordinary remedy of [the Correction of Errors Statute] might quickly become a standard method of review for any taxpayer who could find a factual error on his property record card even several years after his normal appeal time has expired.”); Springfield, supra, 3 N.J.Tax at 95 (“To permit plaintiff to rectify its omission by means

11
Brown v. Browngreen
njsuperctappdiv · 1986 · cited in 1 New Jersey opinions naming this issue, 1988–1988
1 sentence

1988Cf. Brown v. Brown, 208 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 (7)

CaseCitedYears
McElwee v. Ocean City green
njtaxct · 1985
2 sentences

2004The court held that because the “alleged mistake involves an assessor’s opinion[,] this court is expressly prohibited from considering this complaint under this correction of error [sic] statute.” Id. at 363 .

1994The court held that because the “alleged mistake involves an assessor’s opinion!,] this court is expressly prohibited from considering this complaint under this correction of error statute.” Id. at 363 .

31985–2004
Sabella v. Lacey Tp. neutral
njsuperctappdiv · 1983
2 sentences

1985In support of their position, plaintiffs rely upon the Appellate Division opinion in Sabella v. Lacey Tp., 188 N.J.Super. 500 , 457 A. 2d 1220 (App.Div.1983) wherein it stated: “It is likely that this particular statute, being remedial and prophylactic, should be liberally construed____” Id. at 503 , 457 A. 2d 1220 .

1985In support of their position, plaintiffs rely upon the Appellate Division opinion in Sabella v. Lacey Tp., 188 N.J.Super. 500 , 457 A. 2d 1220 (App.Div.1983) wherein it stated: “It is likely that this particular statute, being remedial and prophylactic, should be liberally construed____” Id. at 503 , 457 A. 2d 1220 .

21983–1985
Hovbilt, Inc. v. Township of Howell green
nj · 1994
2 sentences

1996Plaintiffs contention regarding the correction of error statute, N.J.S.A 54:51A-7, is controlled by Hovbilt, Inc. v. Township of Howell, 138 N.J. 598 , 651 A.2d 77 (1994).

1996Plaintiffs contention regarding the correction of error statute, N.J.S.A 54:51A-7, is controlled by Hovbilt, Inc. v. Township of Howell, 138 N.J. 598 , 651 A.2d 77 (1994).

11996–1996
State v. Kirk green
njsuperctappdiv · 1990
1 sentence

1990Cf. State v. Kirk, 243 N.J.

11990–1990
State v. Marzolf green
njsuperctappdiv · 1977
1 sentence

1979The Appellate Division simply assumed that defendant was a first offender. 152 N.J.

11979–1979
Keane v. State green
md · 1933
2 sentences

1951Sanders v. State, 85 Ind. 318 (1882); Keane v. State, 164 Md. 685 (1933).

1951Sanders v. State, 85 Ind. 318 (1882); Keane v. State, 164 Md. 685 (1933).

11951–1951
Sanders v. State green
ind · 1882
2 sentences

1951Sanders v. State, 85 Ind. 318 (1882); Keane v. State, 164 Md. 685 (1933).

1951Sanders v. State, 85 Ind. 318 (1882); Keane v. State, 164 Md. 685 (1933).

11951–1951

Where else courts name it

UT 365 (1896–2025) NY 28 (1871–2022) AL 23 (1847–1993) MO 23 (1893–2022) TN 23 (1926–2026) CA 20 (1864–2025) FL 16 (1939–2021) IN 14 (1897–2024) NJ 14 (1951–2013) IL 14 (1904–2005) GA 13 (1931–2026) OR 12 (1927–2025) VA 12 (1838–2018) MA 12 (1869–2020) CT 11 (1932–2026) PA 11 (1909–2024) MD 11 (1911–2017) TX 10 (1921–2018) KY 9 (1914–2021) NE 8 (1917–2009) IA 7 (1880–2022) WA 7 (1930–2025) LA 7 (1970–2025) MI 7 (1908–2021) OH 7 (1924–2023) OK 6 (1916–2016) ME 5 (1949–2023) WV 5 (1900–2022) AR 5 (1918–2010) VT 5 (1860–1966) HI 4 (1909–2003) ID 4 (1922–2006) CO 4 (1924–1977) AZ 4 (1912–2021) MT 4 (1903–1999) ND 4 (1980–2020) KS 4 (1924–1995) WI 3 (1938–1994) NM 3 (2022–2023) DE 3 (1974–2015) MN 3 (2000–2025) SC 3 (1938–2005) NC 3 (1880–1987) SD 2 (2022–2024)

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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