good cause standard (New Jersey) · Go Syfert
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good cause standard in New Jersey

66 New Jersey opinions name it 3 courts 1981–2026 19 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 (29)

CaseFollowedCited
Ghandi v. Cespedesgreen
njsuperctappdiv · 2007 · cited in 10 New Jersey opinions naming this issue, 2007–2025
2 sentences

2025The proper standard for the court to consider plaintiff's reinstatement application under Rule 1:13-7(a) was good cause. "[T]he term, 'good cause,' evades a precise definition." Ibid. "[C]ourts applying the good cause standard must exercise 'sound discretion in light of the facts and circumstances of the particular case considered in the context of the purposes of the Court Rule being applied.'" Ibid. (quoting Ghandi v. Cespedes, 390 N.J.

2024Notwithstanding the adoption of the good cause standard, we are satisfied that, absent a finding of A-2423-21 11 fault by the plaintiff and prejudice to the defendant, a motion to restore under the rule should be viewed with great liberality. [Gandhi v. Cespedes, 390 N.J.

310
Rivera v. Board of Reviewgreen
nj · 1992 · cited in 5 New Jersey opinions naming this issue, 2018–2026
2 sentences

2019See Rivera v. Bd. of Review, 127 N.J. 578, 585-86, 591 (1992) (holding that due process required a good cause exception to allow late appeals from unemployment compensation decisions).

2018The good cause exception to the twenty-day time limit on unemployment- appeals filings, codified pursuant to our Supreme Court's holding in Rivera v. Board of Review, 127 N.J. 578 (1992), allows tardy filings where an appellant shows: "1.

35
Panagioti L. Giannakopoulos v. Mid State Mallgreen
njsuperctappdiv · 2014 · cited in 4 New Jersey opinions naming this issue, 2020–2026
2 sentences

2020"In applying the good cause standard for reinstating a complaint under Rule 1:13-7(a), 'we are satisfied that, absent a finding of fault by the plaintiff and prejudice to the defendant, a motion to restore under the rule A-2628-18T4 9 should be viewed with great liberality.'" Giannakopoulos v. Mid State Mall, 438 N.J.

2020In our application of the good cause standard for reinstatement under Rule 1:13-7(a), we have therefore determined "that, absent a finding of fault by the plaintiff and prejudice to the defendant, a motion to restore under the rule should be viewed with great liberality." Giannakopoulos, 438 N.J.

34
Matter of Kimber Petroleum Corp.green
nj · 1988 · cited in 3 New Jersey opinions naming this issue, 1988–1995
2 sentences

1988See, however, Kimber, supra for the holding of the Court that (1) a good-cause defense by necessary implication is provided under the treble damages provision of the Spill Act, (2) good-cause defenses include challenges to the reasonableness of the costs assessed, and (3) the DEP has the authority to seek removal costs from dischargers while controlling remedial action and obtain treble damages upon failure to pay such costs. [ 110 N.J. at 86 , 539 A. 2d 1181 ] The Legislature's resolve to control the enormity of New Jersey's toxic tort problem is evident throughout the entirety of the Spill C

1988See, however, Kimber, supra for the holding of the Court that (1) a good-cause defense by necessary implication is provided under the treble damages provision of the Spill Act, (2) good-cause defenses include challenges to the reasonableness of the costs assessed, and (3) the DEP has the authority to seek removal costs from dischargers while controlling remedial action and obtain treble damages upon failure to pay such costs. [ 110 N.J. at 86 , 539 A. 2d 1181 ] The Legislature's resolve to control the enormity of New Jersey's toxic tort problem is evident throughout the entirety of the Spill C

23
Kanaszka v. Kunengreen
njsuperctappdiv · 1998 · cited in 2 New Jersey opinions naming this issue, 2026–2026
2 sentences

2026A purpose of the good cause requirement for dissolving an FRO is to prevent one party from "relitigat[ing] the FRO hearing." Id. at 16.; see also Kanaszka, 313 N.J.

2026Super. at 435 ).] We acknowledge the purpose of the good cause requirement for dissolving an FRO is to prevent one party from "relitigate[ing] the FRO hearing." Id. at 16; see also Kanaszka, 313 N.J.

22
Garzon v. Board of Reviewgreen
njsuperctappdiv · 2004 · cited in 2 New Jersey opinions naming this issue, 2020–2026
2 sentences

2026Rivera, 127 N.J. at 587 ; see also Garzon, 370 N.J.

2020To support her claim she was substantially prevented from reporting, as required to find good cause, Wright cites Rivera v. Bd. of Review, 127 N.J. 578, 580-81, 589-90 (1992) (holding the Department of Labor's repayment notification process was inadequate to protect the due process right to appeal the denial of unemployment benefits of a non-English speaking migrant farmworker who lived in Puerto Rico five months a year) and Garzon v. Bd. of Review, 370 N.J.

22
State v. Younggreen
njsuperctappdiv · 1981 · cited in 2 New Jersey opinions naming this issue, 1988–2019
2 sentences

2019To protect the confidentiality of jury deliberations, Rule 1:16-1 prohibits the parties and any attorney from interviewing jurors, "[e]xcept by leave of court A-3820-17T2 11 granted on good cause[.]" "More than a mere possibility of a tainted verdict must exist to satisfy the good cause requirement." State v. Young, 181 N.J.

1988See State v. Young, 181 N.J.

22
Cassini v. City of Orangegreen
njtaxct · 1997 · cited in 2 New Jersey opinions naming this issue, 2018–2018
2 sentences

2018Thus, in Cassini v. City of Orange, 16 N.J.

2018Thus, in Cassini v. City of Orange, 16 N.J.

22
Lederman v. PRUDENTIAL LIFE INS. CO. OF AMERICA, INC.green
njsuperctappdiv · 2006 · cited in 2 New Jersey opinions naming this issue, 2008–2008
2 sentences

2008Id. at 380-83, 897 A. 2d 362 .

2008Id. at 380-83, 897 A. 2d 362 .

22
The Northern Arapahoe Tribe v. Hodelgreen
ca10 · 1987 · cited in 2 New Jersey opinions naming this issue, 2002–2002
2 sentences

2002In Northern Arapahoe Tribe v. Hodel, 808 F.2d 741, 752 (10th Cir.1987), the court upheld interim regulations restricting hunting on an Indian reservation, promulgated without prepublication notice and comment, because the imminent endangerment of wildlife constituted a good cause exception to the rule.

2002In Northern Arapahoe Tribe v. Hodel, 808 F. 2d 741, 752 (10th Cir.1987), the court upheld interim regulations restricting hunting on an Indian reservation, promulgated without prepublication notice and comment, because the imminent endangerment of wildlife constituted a good cause exception to the rule.

22
Baskett v. KWOKLEUNG CHEUNGgreen
njsuperctappdiv · 2011 · cited in 4 New Jersey opinions naming this issue, 2018–2025
2 sentences

2025In applying the good cause standard in Baskett, we expressed concern with an attorney's "lack of attention" to the case which caused a considerable delay in moving to reinstate the complaint following a dismissal under Rule 1:13-7. 422 N.J.

2020The court's order inexplicably departs from established policies, the good cause standard for reinstatement of a complaint under Rule 1:13-7(a), see, e.g., Baskett, 422 N.J.

14
Hammock Ex Rel. Hammock v. Hoffmann-LaRoche, Inc.green
nj · 1995 · cited in 4 New Jersey opinions naming this issue, 2006–2025
2 sentences

2025The appellate court read the good cause exception in N.J.S.A. 2C:52-19, which the parties had not raised, to require the trial court to “analyze[] the facts of this case by applying Loigman and Rivera.” As to the sealing of court documents, the Appellate Division concluded the trial court “should not have sealed the entire file without finding good cause to overcome the strong presumption of public access to court records.” It directed the court, on remand, to undertake the analysis required by Rules 1:2-1(c) and 1:38-11 and Hammock v. Hoffmann-LaRoche, Inc., 142 N.J. 356, 380-83 (1995), “befo

2008In doing so, the Court summarized its review of precedent and noted that "[t]here is a presumption of public access to documents and materials filed with a court in connection with civil litigation." Id. at 375 , 662 A. 2d 546 .

14
Delaware Valley Wholesale Florist, Inc. v. Addaliagreen
njsuperctappdiv · 2002 · cited in 3 New Jersey opinions naming this issue, 2020–2021
2 sentences

2021Instead, courts applying the good cause standard must exercise "sound discretion in light of the facts and A-2505-19 15 circumstances of the particular case considered in the context of the purposes of the Court Rule being applied." Ibid. (quoting Delaware Valley Wholesale Florist, Inc. v. Addalia, 349 N.J.

2020The good cause standard in Rule 4:21A-4(f) is to be equated with the good cause standard contained in Rule 4:50-1, so that the reasons offered by the movant in 4 The motion must be filed within twenty days "of the date of service on the non-appearing party by the appearing party." Ibid.

13
Mitchell v. United States Department of Housing & Urban Developmentgreen
cand · 1983 · cited in 2 New Jersey opinions naming this issue, 1984–1987
2 sentences

1987As to the argument that the regulation was contrary to legislative intent, the court first examined the language of the statute: [I]n amended section 1437f Congress used the phrase `terminate the tenancy.' If Congress had intended the good cause requirement to be applicable only to mid-lease evictions, it could have easily selected the phrase `terminate the *13 lease.' Congress did therefore appear to require good cause for non-renewal of an assisted lease. [ Id. at 708-709 (emphasis supplied)].

1987The court in Mitchell, supra, 569 F. Supp. at 708-709 , encountered, and similarly rejected, this proposition: "The good cause requirement for non-renewal is not an onerous burden upon the landlord.

12
Leitner v. Toms River Regional Schoolsgreen
njsuperctappdiv · 2007 · cited in 1 New Jersey opinions naming this issue, 2024–2024
2 sentences

2024Plaintiffs posit they met the good cause standard under Hollywood Café, and Leitner v. Toms River Regional Schools, 392 N.J.

2024In Leitner, we examined whether the plaintiffs satisfied the good cause standard in their motion to extend discovery that was returnable before the discovery end-date. 392 N.J.

11
United States v. Valverdegreen
ca9 · 2010 · cited in 1 New Jersey opinions naming this issue, 2023–2023
1 sentence

2023A federal "[a]gency must overcome a high bar if it seeks to invoke the good cause exception to bypass the notice and comment requirement." United States v. Valverde, 628 F.3d 1159, 1164 (9th Cir. 2010).

11
State v. Smithgreen
nj · 2012 · cited in 1 New Jersey opinions naming this issue, 2022–2022
1 sentence

2022Further, the State should have undertaken a less restrictive position A-2683-21 11 consistent with its "primary duty," which "is not to obtain convictions, but to see that justice is done." State v. Smith, 212 N.J. 365, 402-03 (2012); see also State v. Garcia, 245 N.J. 412 , 418 (2021) ("Prosecutors are required to turn square corners because their overriding duty is to do justice." ).

11
State v. Del Finogreen
nj · 1985 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021Accordingly, "[w]hat constitutes good cause or delay will depend upon the circumstances." State v. Del Fino, 100 N.J. 154, 160 (1985).

11
Burns v. Belafskygreen
njsuperctappdiv · 1999 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021Div. 1993); and whether granting a good cause exception comports with the overall purpose of the applicable statute, Burns v. Belafsky, 326 N.J.

11
Utley v. Board of Review, Department of Laborgreen
nj · 2008 · cited in 1 New Jersey opinions naming this issue, 2018–2018
11
Lourdes Medical Center v. Board of Reviewgreen
nj · 2009 · cited in 1 New Jersey opinions naming this issue, 2018–2018
1 sentence

2018Ctr., 197 N.J. at 364 (second alteration in original) (quoting Utley v Bd. of Review, 194 N.J. 534, 543 (2008)). 6 N.J.A.C. 1:12-14.4 became effective on August 1, 1994, 26 N.J.R. 3154-56 (Aug. 1, 1994), and was readopted effective on July 29, 1999, 31 N.J.R. 2603(a) (Sept. 7, 1999).

11
US Bank, N.A. v. Houghgreen
nj · 2012 · cited in 1 New Jersey opinions naming this issue, 2018–2018
11
O'CONNOR v. Abraham Altusgreen
nj · 1975 · cited in 1 New Jersey opinions naming this issue, 2017–2017
11
Klier v. Sordoni Skanska Const. Co.green
njsuperctappdiv · 2001 · cited in 1 New Jersey opinions naming this issue, 2015–2015
11
Steven H. Lawrence v. Mars, Incorporatedgreen
ca4 · 1992 · cited in 1 New Jersey opinions naming this issue, 1992–1992
11
State v. Dolinergreen
nj · 1984 · cited in 1 New Jersey opinions naming this issue, 1990–1990
11
State v. CPS Chemical Co., Inc.green
njsuperctappdiv · 1985 · cited in 1 New Jersey opinions naming this issue, 1990–1990
11
Morristown Mem. Hosp. v. WOKEM MTGE. & REALTY CO.green
njsuperctappdiv · 1983 · cited in 1 New Jersey opinions naming this issue, 1987–1987
11
State v. LaRoccagreen
njsuperctappdiv · 1963 · cited in 1 New Jersey opinions naming this issue, 1981–1981
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 (29)

CaseCitedYears
Hartsfield v. Fantini green
nj · 1997
2 sentences

2020Defense counsel's failure here is not qualitatively different from that found insufficient by the Supreme Court in Hartsfield. 5 We would note that in explaining its imposition of a standard more stringent than the good cause standard applicable when a party fails to appear for arbitration, the Court alluded to the fact that the failure to appear should be viewed as if the party had inadvertently defaulted and applied the Rule 4:50 good cause standard because those movants "have not had an opportunity to argue the merits of their case in court." Hartsfield, 149 N.J. at 618 .

2020Defense counsel's failure here is not qualitatively different from that found insufficient by the Supreme Court in Hartsfield. 5 We would note that in explaining its imposition of a standard more stringent than the good cause standard applicable when a party fails to appear for arbitration, the Court alluded to the fact that the failure to appear should be viewed as if the party had inadvertently defaulted and applied the Rule 4:50 good cause standard because those movants "have not had an opportunity to argue the merits of their case in court." Hartsfield, 149 N.J. at 618 .

22020–2020
Waterside Villas Holdings, LLC v. Monroe Township green
njsuperctappdiv · 2014
2 sentences

2018Thus, “plaintiff’s failure to respond in any fashion to the assessor’s request precluded plaintiff from asserting a good cause claim.” Ibid. (citation and internal quotation marks omitted).1 The court however, recognized that a non-response may be justified if the “the request 1 The trial court rulings prior to Waterside, supra, and relied upon by plaintiff, also echoed the requirement for a response.

2018Thus, “plaintiff’s failure to respond in any fashion to the assessor’s request precluded plaintiff from asserting a good cause claim.” Ibid. (citation and internal quotation marks omitted).1 The court however, recognized that a non-response may be justified if the “the request 1 The trial court rulings prior to Waterside, supra, and relied upon by plaintiff, also echoed the requirement for a response.

22018–2018
Doe v. Poritz green
nj · 1995
2 sentences

1995The County Prosecutor, in opposing the registrant's motion for leave to file a late application for review, cites our Supreme Court's holding in Doe v. Poritz, 142 N.J. 1 , 662 A. 2d 367 (1995) as having "established a strict time frame in which the classification and notification process should be completed." The Prosecutor further cites the Attorney General's "Outline of Procedure for Hearings on Objections to Megan's Law Tier 2 and Tier 3 Classification and Manner of Notification Determinations," noting *405 that it states that a registrant has fourteen days to object to Tier 2 or Tier 3 cl

1995The County Prosecutor, in opposing the registrant's motion for leave to file a late application for review, cites our Supreme Court's holding in Doe v. Poritz, 142 N.J. 1 , 662 A. 2d 367 (1995) as having "established a strict time frame in which the classification and notification process should be completed." The Prosecutor further cites the Attorney General's "Outline of Procedure for Hearings on Objections to Megan's Law Tier 2 and Tier 3 Classification and Manner of Notification Determinations," noting *405 that it states that a registrant has fourteen days to object to Tier 2 or Tier 3 cl

21995–1995
Pennzoil Co. v. Texaco Inc. green
scotus · 1987
2 sentences

1988Such a problem would not arise, however, if a good-cause defense was read into the Act. [6] Cf. Pennzoil v. Texaco, ___ U.S. ___, ___-___ & nn. 10-11, 107 S.Ct. 1519 , 1526-27 & nn. 10-11, 95 L.Ed. 2d 1 , 16-17 & nn. 10-11 (1987) (federal court should abstain from determining validity of state statute under the federal constitution in part to give the state courts an opportunity to modify the statute's interpretation in light of a state constitutional provision). [7] The need for action in this area, and, in particular, for state government action, was shown by a recent report that stated that

1988Such a problem would not arise, however, if a good-cause defense was read into the Act. [6] Cf. Pennzoil v. Texaco, ___ U.S. ___, ___-___ & nn. 10-11, 107 S.Ct. 1519 , 1526-27 & nn. 10-11, 95 L.Ed. 2d 1 , 16-17 & nn. 10-11 (1987) (federal court should abstain from determining validity of state statute under the federal constitution in part to give the state courts an opportunity to modify the statute's interpretation in light of a state constitutional provision). [7] The need for action in this area, and, in particular, for state government action, was shown by a recent report that stated that

21988–1988
State v. Johnson green
njsuperctappdiv · 1980
1 sentence

2022Our decision in State v. Johnson presents facts that are most similar to this appeal, in that it involved our review of the resentencing of the defendant, not under a court rule, but rather a statute that employed the good cause standard. 176 N.J.

12022–2022
In the Matter of John Restrepo, Department of Corrections green
njsuperctappdiv · 2017
1 sentence

2022Therefore, the CSC's final administrative action was timely whether the extension is considered valid pursuant to the good cause standard of N.J.S.A. 52:14B-10(c) and N.J.A.C. 1:1- 18.8(e), or the discretionary standard of N.J.S.A. 40A:14-204 and Restrepo, 449 N.J.

12022–2022
State v. Herrerra green
nj · 2012
2 sentences

2021Without expressly invoking the good cause standard, the Court reached a similar conclusion in State v. Herrerra, 211 N.J. 308 (2012). (pp. 30-33) 4 8.

2021In that case, the defendants sought, in a post- conviction setting, to investigate evidence of racial profiling by compelling the State to produce the arresting officer’s personnel file, without presenting evidence that the motor vehicle stop leading to the defendants’ arrest on narcotics and attempted murder charges was racially motivated. 211 N.J. at 313 .

12021–2021
Burns v. Belafsky green
nj · 2001
1 sentence

2021Super. 462, 471 (App. Div. 1999), aff'd, 166 N.J. 466 (2001).

12021–2021
The Pitney Bowes Bank, Inc. v. Abc Caging Fulfillment green
njsuperctappdiv · 2015
1 sentence

2020Super. at 384-85 , and constitutes an abuse of discretion, see Pitney Bowes Bank, Inc., 440 N.J.

12020–2020
Yardville Supply Co. v. Board of Review, Dept. of Labor green
nj · 1989
12018–2018
Brady v. Board of Review green
nj · 1997
12018–2018
In Re Election Law Enforcement Commission Advisory Opinion No. 01-2008 green
nj · 2010
1 sentence

2018N.J.A.C. 1:12-14.4(b)'s mandate that such dismissals shall be vacated where good cause is shown is consistent with the policy underlying New Jersey's Unemployment Compensation Law, N.J.S.A. 43:21-1 to -56 (the Act): to "provide some income for the worker earning nothing, because he is out of work through no fault or act of his own." Brady, 152 N.J. at 212 (quoting 10 A-5697-16T4 In any event, the Appeal Tribunal and Board mistakenly applied N.J.A.C. 1:12-14.4(a)'s good cause standard in its determination of good cause under N.J.A.C. 1:12-14.4(b), and therefore did not consider or interpret the

12018–2018
Depos v. Depos green
njch · 1997
12008–2008
James v. Bessemer Processing Co. green
nj · 1998
12007–2007
State v. LaResca green
njsuperctappdiv · 1993
12003–2003
State v. Preciose green
nj · 1992
12002–2002
Wentzel v. Huebner green
sd · 1960
11999–1999
Steinmann v. State, Dept. of Treasury green
nj · 1989
11999–1999
Rova Farms Resort, Inc. v. Investors Insurance Co. of America green
nj · 1974
11999–1999
State v. Lanza neutral
njsuperctappdiv · 1960
11998–1998
State v. Ramseur green
nj · 1987
11998–1998
In Re Bailey neutral
nj · 1971
11998–1998
Barry v. Arrow Pontiac, Inc. green
nj · 1985
11992–1992
Matter of Vey green
nj · 1991
11992–1992
Sidney Diggs, IV v. Pepsi-Cola Metropolitan Bottling Co., Inc. green
ca6 · 1989
11992–1992
Ullmann v. Hartford Fire Ins. Co. green
njsuperctappdiv · 1965
11991–1991
Ivy Hill Park Apartments v. Martin green
njsuperctappdiv · 1985
11987–1987
Swann v. Gastonia Housing Authority green
ca4 · 1982
11984–1984
Nemeth v. Otis Elevator Co., Inc. green
njsuperctappdiv · 1959
11984–1984

Statutes the citing opinions construe

NJ § N.J. Stat. § 43:21-6 (3)

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

CA 141 (1937–2026) TX 118 (1945–2026) VA 74 (1941–2026) NJ 66 (1981–2026) AL 55 (1906–2026) PA 55 (1805–2026) IA 48 (1975–2026) MI 46 (1904–2026) NY 41 (1823–2025) ME 38 (1824–2023) CT 37 (1986–2026) MO 37 (1881–2019) FL 32 (1972–2025) MA 31 (1993–2025) NV 28 (1979–2025) KS 26 (1899–2026) IL 24 (1853–2024) WA 24 (1975–2025) MD 23 (1941–2025) ID 20 (1998–2025) UT 19 (1979–2025) CO 18 (1979–2026) DC 15 (1977–2026) LA 14 (2001–2024) MT 13 (1986–2023) OH 13 (1996–2024) NM 12 (1991–2024) IN 12 (1837–2013) AK 12 (1987–2025) OR 12 (1997–2024) AZ 11 (1965–2024) DE 11 (2014–2026) VT 10 (1831–2026) WI 10 (1982–2025) NC 9 (1953–2022) WV 9 (1980–2023) SC 7 (1986–2026) NE 6 (1981–2026) HI 5 (1982–2021) MS 5 (1872–2003) ND 4 (2007–2020) RI 4 (1995–2011) GA 4 (1918–1970) MN 3 (2003–2015) TN 3 (2014–2026) SD 3 (1997–2010) NH 3 (1808–2022) OK 2 (2003–2009) WY 2 (1991–2011) AR 2 (1933–1995) KY 2 (2016–2018)

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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