modification rule (New Jersey) · Go Syfert
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modification rule in New Jersey

14 New Jersey opinions name it 3 courts 1949–2026 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 (9)

CaseFollowedCited
Konzelman v. Konzelmangreen
nj · 1999 · cited in 2 New Jersey opinions naming this issue, 2021–2022
2 sentences

2022Lepis imposes a fairness dimension to the modification analysis, even when the parties themselves have set the parameters of alimony. 83 N.J. at 148 - 49; see also Konzelman, 158 N.J. at 194 .

2021See id. at 148-49 ; see also Konzelman v. Konzelman, 158 N.J. 185, 194 (1999) ("Courts have continuing power to oversee divorce agreements . . . [and] enforce such agreements only to the extent they are fair and equitable.") (internal citations and quotations omitted); Guglielmo v. Guglielmo, 253 N.J.

22
Lepis v. Lepisgreen
nj · 1980 · cited in 2 New Jersey opinions naming this issue, 2021–2022
2 sentences

2022Lepis imposes a fairness dimension to the modification analysis, even when the parties themselves have set the parameters of alimony. 83 N.J. at 148 - 49; see also Konzelman, 158 N.J. at 194 .

2022"In deciding whether to modify an agreement due to changed circumstances, 'the proper criteria are whether the change in circumstance is continuing and whether the agreement or decree has made explicit provision for the change.'" Quinn, 225 N.J. at 49 (quoting Lepis, 83 N.J. at 152 ).

12
Morton v. 4 Orchard Land Trustgreen
nj · 2004 · cited in 1 New Jersey opinions naming this issue, 2026–2026
1 sentence

2026"A written contract is formed when there is a 'meeting of the minds' between the parties, evidenced by a written offer and an unconditional, written acceptance." Morton v. 4 Orchard Land Tr., 180 N.J. 118, 129-30 (2004) (quoting Johnson & Johnson v. Charmley Drug Co., 11 N.J. 526, 538-39 (1953)).

11
Johnson & Johnson v. Charmley Drug Co.green
nj · 1953 · cited in 1 New Jersey opinions naming this issue, 2026–2026
1 sentence

2026"A written contract is formed when there is a 'meeting of the minds' between the parties, evidenced by a written offer and an unconditional, written acceptance." Morton v. 4 Orchard Land Tr., 180 N.J. 118, 129-30 (2004) (quoting Johnson & Johnson v. Charmley Drug Co., 11 N.J. 526, 538-39 (1953)).

11
Guglielmo v. Guglielmogreen
njsuperctappdiv · 1992 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021See id. at 148-49 ; see also Konzelman v. Konzelman, 158 N.J. 185, 194 (1999) ("Courts have continuing power to oversee divorce agreements . . . [and] enforce such agreements only to the extent they are fair and equitable.") (internal citations and quotations omitted); Guglielmo v. Guglielmo, 253 N.J.

11
State v. Bursteingreen
nj · 1981 · cited in 1 New Jersey opinions naming this issue, 2008–2008
2 sentences

2008See Burstein, supra, 85 N.J. at 406-07 , 427 A.2d 525 .

2008See Burstein, supra, 85 N.J. at 406-07 , 427 A.2d 525 .

11
Commonwealth Ex Rel. Comptroller of Virginia v. Skeensgreen
vactapp · 1994 · cited in 1 New Jersey opinions naming this issue, 1999–1999
1 sentence

1999The court simply allows a source of funds, indirectly attributable to a parent, to be used to satisfy the parent's court-ordered support obligation. [ Id. at 435.] In Brewer v. Brewer, 244 Neb. 731 , 509 N.W. 2d 10 (1993), the Nebraska Supreme Court similarly observed that "a modification hearing implies a change in the amount of the court's order on behalf of the minor child, and consequently, requires a material change in circumstances.

11
Brewer v. Brewergreen
neb · 1993 · cited in 1 New Jersey opinions naming this issue, 1999–1999
2 sentences

1999The court simply allows a source of funds, indirectly attributable to a parent, to be used to satisfy the parent's court-ordered support obligation. [ Id. at 435.] In Brewer v. Brewer, 244 Neb. 731 , 509 N.W. 2d 10 (1993), the Nebraska Supreme Court similarly observed that "a modification hearing implies a change in the amount of the court's order on behalf of the minor child, and consequently, requires a material change in circumstances.

1999The court simply allows a source of funds, indirectly attributable to a parent, to be used to satisfy the parent's court-ordered support obligation. [ Id. at 435.] In Brewer v. Brewer, 244 Neb. 731 , 509 N.W. 2d 10 (1993), the Nebraska Supreme Court similarly observed that "a modification hearing implies a change in the amount of the court's order on behalf of the minor child, and consequently, requires a material change in circumstances.

11
Frame v. Kotharigreen
nj · 1989 · cited in 1 New Jersey opinions naming this issue, 1995–1995
2 sentences

1995Rarely will a member of the patient’s family contemporaneously observe the immediate consequences of the defendant’s misdiagnosis, and even more rarely will the results of the misdiagnosis be the injury or death of a loved one contemplated by the gruesome scene portrayed in Portee . [Id. at 647-48, 560 A.2d 675 .] Accordingly, the Frame opinion offers a modification of the standard Portee framework, to permit bystander recovery of emotional-distress damages in a malpractice context that does not meet the Portee guidelines: “In an appropriate case, if a family member witnesses the physician’s m

1995Rarely will a member of the patient's family contemporaneously observe the immediate consequences of the defendant's misdiagnosis, and even more rarely will the results of the misdiagnosis be the injury or death of a loved one contemplated by the gruesome scene portrayed in Portee. [ Id. at 647-48, 560 A. 2d 675 .] Accordingly, the Frame opinion offers a modification of the standard Portee framework, to permit bystander recovery of emotional-distress damages in a malpractice context that does not meet the Portee guidelines: "In an appropriate case, if a family member witnesses the physician's

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 (11)

CaseCitedYears
Daubert v. Merrell Dow Pharmaceuticals, Inc. green
scotus · 1993
2 sentences

2026In February of 2023, however, the New Jersey Supreme Court in Olenowski I held that going forward criminal courts should apply a modification of the test set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). 253 N.J. at 151-52.

2026That test requires courts to assess "whether the reasoning or methodology underlying the testimony is scientifically valid and [] whether that reasoning or methodology properly can be applied to the facts in issue." Id. at 147 (emphasis omitted) (quoting Daubert, 509 U.S. at 592-93 ).

12026–2026
Cathleen Quinn v. David J. Quinn (074411) green
nj · 2016
1 sentence

2022"In deciding whether to modify an agreement due to changed circumstances, 'the proper criteria are whether the change in circumstance is continuing and whether the agreement or decree has made explicit provision for the change.'" Quinn, 225 N.J. at 49 (quoting Lepis, 83 N.J. at 152 ).

12022–2022
Cesare v. Cesare green
nj · 1998
1 sentence

2017Our standard of review is as follows. "[F]indings by the trial court are binding on appeal when supported by adequate, substantial, credible evidence." Cesare v. Cesare, 154 N.J. 394 , 7 A-2542-14T1 411-12 (1998) (citing Rova Farms Resort, Inc. v. Inv'rs Ins.

12017–2017
McFadden v. McFadden green
pa · 1989
2 sentences

1990McFadden v. McFadden, 386 Pa.Super. 506 , 563 A. 2d 180 (Super.Ct. 1989).

1990McFadden v. McFadden, 386 Pa.Super. 506 , 563 A. 2d 180 (Super.Ct. 1989).

11990–1990
Fasolo v. Pensions Div. Trustees green
njsuperctappdiv · 1981
2 sentences

1985In Fasolo v. Pensions Div. Trustees, 181 N.J.Super. 434 , 438 A. 2d 328 (App.Div.1981), the court found that the Public Employees’ Retirement System (PERS) had required Fasolo to overpay certain contributions to the PERS fund and that he was underpaid by the pension payments he later received.

1985In Fasolo v. Pensions Div. Trustees, 181 N.J.Super. 434 , 438 A. 2d 328 (App.Div.1981), the court found that the Public Employees’ Retirement System (PERS) had required Fasolo to overpay certain contributions to the PERS fund and that he was underpaid by the pension payments he later received.

11985–1985
Dunlap v. Dunlap green
· 1930
2 sentences

1957Rev., at p. 1030); Peaslee, C.J., in Dunlap v. Dunlap, 84 N.H. 352 , 150 A. 905, 914 , 71 A.L.R. 1055 ( Sup. Ct. 1930), supply added cogency to the effectuation of a modification of the rule of immunity to the limited extent involved in such a situation (apart, of course, from any specific consideration as to whether there was insurance in the case before us).

1957Rev., at p. 1030); Peaslee, C.J., in Dunlap v. Dunlap, 84 N.H. 352 , 150 A. 905, 914 , 71 A.L.R. 1055 ( Sup. Ct. 1930), supply added cogency to the effectuation of a modification of the rule of immunity to the limited extent involved in such a situation (apart, of course, from any specific consideration as to whether there was insurance in the case before us).

11957–1957
Superintendent & Trustees of Public Schools v. Bennett green
nj · 1859
1 sentence

1955Where one of two innocent persons must sustain a loss, the law casts it upon him who has agreed to sustain it, or rather the law leaves it where the agreement of the parties has put it; the law will not insert, for the benefit of one of the parties, by construction, an exception which the parties have not, either by design or neglect, inserted in their engagement." ( 27 N.J.L., at page 519 .) Recent developments have introduced into the law a modification of this rule, in certain instances, which has come to be called the doctrines of implied condition and frustration of purpose, thoroughly di

11955–1955
Edwards v. Leopoldi green
nj · 1952
1 sentence

1955Super. 43 ( App. Div. 1952), certif. denied 10 N.J. 347 (1952).

11955–1955
Edwards v. Leopoldi green
njsuperctappdiv · 1952
1 sentence

1955Where one of two innocent persons must sustain a loss, the law casts it upon him who has agreed to sustain it, or rather the law leaves it where the agreement of the parties has put it; the law will not insert, for the benefit of one of the parties, by construction, an exception which the parties have not, either by design or neglect, inserted in their engagement." ( 27 N.J.L., at page 519 .) Recent developments have introduced into the law a modification of this rule, in certain instances, which has come to be called the doctrines of implied condition and frustration of purpose, thoroughly di

11955–1955
Jones v. U-Drive-It Company green
nj · 1931
1 sentence

1954Such, I submit, is the reason and spirit of the New Jersey Act, a modification of the rule of Manowitz v. Kanov, supra .

11954–1954
Sherrer v. Sherrer green
scotus · 1948
2 sentences

1949The modification to which that principle is subjected when both parties appeared in the divorce proceedings, Sherrer v. Sherrer, 334 U. S. 343 , 92 L.

1949The modification to which that principle is subjected when both parties appeared in the divorce proceedings, Sherrer v. Sherrer, 334 U. S. 343 , 92 L.

11949–1949

Where else courts name it

CA 127 (1892–2026) TX 102 (1921–2026) IN 52 (1861–2026) MO 50 (1851–2020) IL 46 (1863–2026) NY 43 (1897–2024) NE 41 (1895–2024) AL 39 (1867–2018) FL 35 (1932–2026) MS 32 (1957–2024) OR 30 (1898–2025) IA 30 (1928–2026) PA 29 (1917–2026) VA 24 (1902–2026) AZ 21 (1926–2026) WA 21 (1896–2025) OH 20 (1975–2026) UT 19 (1938–2023) NC 18 (1889–2025) TN 18 (1904–2026) CO 17 (1900–2026) KS 17 (1878–2026) VT 17 (1984–2024) MD 16 (1910–2014) MI 16 (1879–2025) CT 16 (1975–2021) MA 14 (1931–2025) NJ 14 (1949–2026) WY 13 (1905–2019) ND 12 (1992–2020) MN 11 (1922–2026) MT 11 (1900–1993) WV 10 (1923–2024) OK 10 (1904–2018) WI 10 (1896–2025) AK 10 (1973–2026) KY 10 (1912–2026) NH 9 (1844–2015) LA 9 (1938–2002) SD 9 (1930–2024) GA 9 (1894–2026) SC 8 (1892–2016) HI 7 (1896–2019) AR 7 (1918–2022) ID 6 (1949–2026) DC 6 (1994–2016) NV 6 (1878–2016) RI 4 (1903–1995) NM 3 (1962–2013) ME 3 (1905–2016)

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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