fraudulent concealment claim (New Jersey) · Go Syfert
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fraudulent concealment claim in New Jersey

12 New Jersey opinions name it 2 courts 2008–2025 7 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 (3)

CaseFollowedCited
Rosenblit v. Zimmermangreen
nj · 2001 · cited in 9 New Jersey opinions naming this issue, 2008–2025
2 sentences

2025To prevail on a fraudulent concealment claim, a plaintiff must demonstrate: (1) That defendant in the fraudulent concealment action had a legal obligation to disclose evidence in connection with an existing or pending litigation; (2) That the evidence was material to the litigation; (3) That plaintiff could not reasonably have obtained access to the evidence from another source; (4) That defendant intentionally withheld, altered or destroyed the evidence with purpose to disrupt the litigation; (5) That plaintiff was damaged in the underlying action by having to rely on an evidential record tha

2025To prevail on a fraudulent concealment claim, a plaintiff must demonstrate: (1) That defendant in the fraudulent concealment action had a legal obligation to disclose evidence in connection with an existing or pending litigation; (2) That the evidence was material to the litigation; (3) That plaintiff could not reasonably have obtained access to the evidence from another source; (4) That defendant intentionally withheld, altered or destroyed the evidence with purpose to disrupt the litigation; (5) That plaintiff was damaged in the underlying action by having to rely on an evidential record tha

59
Cockerline v. Menendezgreen
njsuperctappdiv · 2010 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025Spoliation "occurs when evidence pertinent to the action is destroyed, thereby interfering with the action's proper administration and disposition." Cockerline v. Menendez, 411 N.J.

11
Trinity Church v. Lawson-Bellgreen
njsuperctappdiv · 2007 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025Trinity Church v. Lawson-Bell, 394 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 (3)

CaseCitedYears
Reyes v. Egner green
njsuperctappdiv · 2009
2 sentences

2021Id. at 459 .

2019Id. at 459 .

22019–2021
Viviano v. CBS, INC. green
njsuperctappdiv · 1991
1 sentence

2025Id. at 122 .

12025–2025
Jerista v. Murray green
nj · 2005
2 sentences

2008On the other hand, an act of spoliation by a third party, including a reckless one, see Jerista v. Murray, 185 N.J. 175, 201-03 , 883 A.2d 350 (2005), will not often give rise to an evidentiary sanction in the trial of the case in chief, but instead will be addressed in a separate proceeding.

2008On the other hand, an act of spoliation by a third party, including a reckless one, see Jerista v. Murray, 185 N.J. 175, 201-03 , 883 A.2d 350 (2005), will not often give rise to an evidentiary sanction in the trial of the case in chief, but instead will be addressed in a separate proceeding.

12008–2008

Where else courts name it

TX 136 (1973–2024) IN 60 (1976–2023) CA 59 (1921–2026) PA 38 (1993–2026) TN 35 (1949–2024) IL 35 (1964–2026) MS 34 (1999–2022) MI 30 (1980–2026) DE 20 (1968–2026) WA 18 (1969–2020) IA 18 (1951–2021) NY 17 (1996–2024) FL 16 (1984–2022) OH 16 (1971–2022) CT 13 (1995–2024) NJ 12 (2008–2025) NH 8 (1974–2023) CO 8 (1982–2016) AZ 8 (1998–2025) NE 7 (1988–2018) MD 7 (1997–2017) MA 7 (1993–2017) NM 6 (1993–2016) UT 6 (1997–2021) MN 6 (1981–2014) MT 6 (1988–2013) SD 5 (1957–2023) ME 4 (2001–2008) SC 4 (1998–2009) AL 3 (1986–2023) NC 3 (1988–2018) ID 3 (1964–2020) MO 3 (1985–2015) WV 3 (1990–2025) AR 2 (1996–2023) GA 2 (2022–2025) KS 2 (1996–1997) HI 2 (2019–2024) DC 2 (1987–1996) WY 2 (2013–2013) NV 2 (2019–2019) AK 2 (1992–2025)

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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