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13 New Jersey opinions name it 2 courts 1965–2025 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.
| Case | Followed | Cited |
|---|---|---|
Zelasko v. Refrigerated Food Expressgreen2 sentences2025However, the special mission exception allows for compensation occurring outside the workplace when the employee is "required to be away from the conventional place of employment[,] if actually engaged in the direct performance of employment duties." Id. at 340 n.8 (alteration in original) (quoting Zelasko v. Refrigerated Food Express, 128 N.J. 329, 336 (1992)). 2017Next, the judge analyzed N.J.S.A. 34:15-36, which prohibits compensation for accidents occurring in areas outside of the employer's control, and the "special mission" exception to the "going and coming" rule which allows compensation if an employee is 1. required to be away from the conventional place of employment; 2. if actually engaged in the direct performance of employment duties. [Zelasko v. Refrigerated Food Express, 128 N.J. 329, 336 (1992).] The judge determined that, because Gould's assignment required her to occasionally travel to other facilities, the first prong of the special mis | 3 | 4 |
Carberry v. Stategreen2 sentences2017As the Court explained in Carter, [w]hen an employee, having identifiable time and space limits on his employment, makes an off-premises journey which would normally not be covered under the usual going and coming rule, the journey may be brought within the course of employment by the fact that the trouble and time of making the journey, or the 8 A-1541-15T4 special inconvenience, hazard, or urgency of making it in particular circumstances, is itself sufficiently substantial to be viewed as an integral part of the service itself. [Ibid. (quoting Carberry v. State, Div. of State Police, 279 N.J 2003When an employee, having identifiable time and space limits on his employment, makes an off-premises journey which would normally not be covered under the usual going and coming rule, the journey may be brought within the course of employment by the fact that the trouble and time of making the journey, or the special inconvenience, hazard, or urgency of making it in the particular circumstances, is itself sufficiently substantial to be viewed as an integral part of the service itself. [Carberry v. State, Div. of State Police, 279 N.J.Super. 114, 120 , 652 A.2d 232 (App.Div.) (quoting 1 Arthur | 1 | 2 |
Domanoski v. Borough of Fanwoodgreen1 sentence2025In a succinct memorandum of decision that accompanied the order, the judge considered whether, based on the facts, joint employment liability was established under Domanoski v. Borough of Fanwood and the special mission doctrine. 237 N.J. | 1 | 1 |
Ehrgott v. Jonesgreen1 sentence2025For travel time to be included as part of this special mission, the travel must be "so integral" to the job itself so as to constitute "a part of the overall mission." Ehrgott v. Jones, 208 N.J. | 1 | 1 |
Mangigian v. Franz Warner Assoc., Inc.green1 sentence1986See Mangigian v. Franz Warner Assoc., Inc., 205 N.J. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Nemchick v. Thatcher Glass Mfg. Co.
green
2 sentences1989Id. at 142 . 1985Id. at 143 . | 2 | 1985–1989 |
Kristiansen v. Morgan
green
1 sentence2022Id. at 244 n.1. | 1 | 2022–2022 |
Wilkins v. Prudential Insurance & Financial Services
green
1 sentence2021He did fall within the special mission exception, because "he was not only permitted, but encouraged, to work away from this office." Id. at 590 . | 1 | 2021–2021 |
Mannes v. Healey
green
1 sentence2017"The special mission exception has fairly well-defined margins." Id. at 417 . | 1 | 2017–2017 |
Hart v. Property Management Systems
green
2 sentences2003When an employee, having identifiable time and space limits on his employment, makes an off-premises journey which would normally not be covered under the usual going and coming rule, the journey may be brought within the course of employment by the fact that the trouble and time of making the journey, or the special inconvenience, hazard, or urgency of making it in the particular circumstances, is itself sufficiently substantial to be viewed as an integral part of the service itself. [Carberry v. State, Div. of State Police, 279 N.J.Super. 114, 120 , 652 A.2d 232 (App.Div.) (quoting 1 Arthur 2003When an employee, having identifiable time and space limits on his employment, makes an off-premises journey which would normally not be covered under the usual going and coming rule, the journey may be brought within the course of employment by the fact that the trouble and time of making the journey, or the special inconvenience, hazard, or urgency of making it in the particular circumstances, is itself sufficiently substantial to be viewed as an integral part of the service itself. [ Carberry v. State, Div. of State Police, 279 N.J.Super. 114, 120 , 652 A. 2d 232 (App.Div.) (quoting 1 Arthu | 1 | 2003–2003 |
State v. MELLAGE
neutral
2 sentences2003When an employee, having identifiable time and space limits on his employment, makes an off-premises journey which would normally not be covered under the usual going and coming rule, the journey may be brought within the course of employment by the fact that the trouble and time of making the journey, or the special inconvenience, hazard, or urgency of making it in the particular circumstances, is itself sufficiently substantial to be viewed as an integral part of the service itself. [Carberry v. State, Div. of State Police, 279 N.J.Super. 114, 120 , 652 A.2d 232 (App.Div.) (quoting 1 Arthur 2003When an employee, having identifiable time and space limits on his employment, makes an off-premises journey which would normally not be covered under the usual going and coming rule, the journey may be brought within the course of employment by the fact that the trouble and time of making the journey, or the special inconvenience, hazard, or urgency of making it in the particular circumstances, is itself sufficiently substantial to be viewed as an integral part of the service itself. [ Carberry v. State, Div. of State Police, 279 N.J.Super. 114, 120 , 652 A. 2d 232 (App.Div.) (quoting 1 Arthu | 1 | 2003–2003 |
Lehigh Navigation Coal Co. v. McConnell
green
2 sentences2000And in Lehigh [Navigation Coal Co. v. McGonnell, 120 N.J.L. 428 , 199 A. 906 (Sup.Ct.1938), aff'd o.b. 121 N.J.L. 583 , 3 A.2d 581 (E. & A.1939) ], compensation was allowed when an employee was killed after his employer had provided a commutation ticket for railroad commutation although the accident occurred 75 to 100 feet from the place where he would board the train. 2000And in Lehigh [Navigation Coal Co. v. McGonnell, 120 N.J.L. 428 , 199 A. 906 (Sup.Ct.1938), aff'd o.b. 121 N.J.L. 583 , 3 A.2d 581 (E. & A.1939) ], compensation was allowed when an employee was killed after his employer had provided a commutation ticket for railroad commutation although the accident occurred 75 to 100 feet from the place where he would board the train. | 1 | 2000–2000 |
Lehigh Navigation Coal Co. v. McGonnell
green
2 sentences2000And in Lehigh [Navigation Coal Co. v. McGonnell, 120 N.J.L. 428 , 199 A. 906 (Sup.Ct.1938), aff'd o.b. 121 N.J.L. 583 , 3 A.2d 581 (E. & A.1939) ], compensation was allowed when an employee was killed after his employer had provided a commutation ticket for railroad commutation although the accident occurred 75 to 100 feet from the place where he would board the train. 2000And in Lehigh [Navigation Coal Co. v. McGonnell, 120 N.J.L. 428 , 199 A. 906 (Sup.Ct.1938), aff'd o.b. 121 N.J.L. 583 , 3 A.2d 581 (E. & A.1939) ], compensation was allowed when an employee was killed after his employer had provided a commutation ticket for railroad commutation although the accident occurred 75 to 100 feet from the place where he would board the train. | 1 | 2000–2000 |
Ricciardi v. Damar Products Co.
green
2 sentences2000Thus in Ricciardi.[v. Damar Products Co., 45 N.J. 54 , 211 A.2d 347 (1965) ], an accident occurring on the way home from a company picnic was held to be compensable within the special mission exception. 2000Thus in Ricciardi.[v. Damar Products Co., 45 N.J. 54 , 211 A.2d 347 (1965) ], an accident occurring on the way home from a company picnic was held to be compensable within the special mission exception. | 1 | 2000–2000 |
Stakonis v. United Advertising Corporation
green
2 sentences1965This is the same result reached in other jurisdictions which hold that a company-sponsored recreational outing is protected by the compensation law. [1] See Stakonis v. United Advertising Co., 110 Conn. 384 , 148 A. 334 ( Sup. Ct. Err. 1930); Dodge v. Wm. 1965This is the same result reached in other jurisdictions which hold that a company-sponsored recreational outing is protected by the compensation law. [1] See Stakonis v. United Advertising Co., 110 Conn. 384 , 148 A. 334 ( Sup. Ct. Err. 1930); Dodge v. Wm. | 1 | 1965–1965 |
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.
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.