ripeness doctrine in New Jersey

7 New Jersey opinions name it 2 courts 1996–2026 3 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)

Case	Followed	Cited
House of Fire v. Zoning Bd.green njsuperctappdiv · 2005 · cited in 3 New Jersey opinions naming this issue, 2024–2026 2 sentences 2026The ripeness doctrine prevents "premature adjudication" or "entangl[ement] . . . in abstract disagreements." House of Fire Christian Church v. Zoning Bd. of Adjustment of City of Clifton, 379 N.J. 2025The ripeness doctrine prevents "premature adjudication" or "entangl[ement] . . . in abstract disagreements." House of Fire Christian Church v. Zoning Bd. of Adjustment of City of Clifton , 379 N.J.	3	3
Abbott Laboratories v. Gardnerred scotus · 1967 · cited in 2 New Jersey opinions naming this issue, 2005–2010 2 sentences 2010The basic rationale of the doctrine of ripeness "is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements... [.]" Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681, 691 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99 , 97 S.Ct. 980 , 51 L.Ed. 2d 192 (1977). 2010The basic rationale of the doctrine of ripeness "is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements... [.]" Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681, 691 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99 , 97 S.Ct. 980 , 51 L.Ed. 2d 192 (1977).	2	2
Robert Murphy v. New Milford Zoning Commissiongreen ca2 · 2005 · cited in 3 New Jersey opinions naming this issue, 2005–2026 2 sentences 2026Super. 526, 547 (App. Div. 2005) (quoting Murphy v. New Milford Zoning Comm'n, A-3175-23 14 402 F.3d 342 , 347 (2d Cir. 2005)). 2005See Murphy v. New Milford Zoning Comm'n, 402 F. 3d 342 , 347, 353-54 (2d Cir.2005) (concluding that the plaintiff's RLUIPA claim was not ripe and noting *1226 that "the ripeness doctrine's `basic rationale is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements'") (quoting Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99, 105 , 97 S.Ct. 980, 984 , 51 L.Ed. 2d 192 (1977)); Taylor Inv., Ltd. v. Upper Darby Tp., 983 F. 2d 1285 ,	1	3
Califano v. Sandersgreen scotus · 1977 · cited in 2 New Jersey opinions naming this issue, 2005–2010 2 sentences 2010The basic rationale of the doctrine of ripeness "is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements... [.]" Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681, 691 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99 , 97 S.Ct. 980 , 51 L.Ed. 2d 192 (1977). 2010The basic rationale of the doctrine of ripeness "is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements... [.]" Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681, 691 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99 , 97 S.Ct. 980 , 51 L.Ed. 2d 192 (1977).	1	2
Hamdan v. Rumsfeldgreen scotus · 2006 · cited in 1 New Jersey opinions naming this issue, 2010–2010 2 sentences 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act	1	1
Anderson v. Greengreen scotus · 1995 · cited in 1 New Jersey opinions naming this issue, 2010–2010 2 sentences 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act	1	1
Texas v. United Statesgreen scotus · 1998 · cited in 1 New Jersey opinions naming this issue, 2010–2010 2 sentences 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act	1	1
Regional Rail Reorganization Act Casesgreen scotus · 1974 · cited in 1 New Jersey opinions naming this issue, 2010–2010 2 sentences 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act 2010Therefore, courts will not decide claims that are "`contingent [upon] future events that may not occur as anticipated, or indeed may not occur at all.'" Hamdan v. Rumsfeld, 548 U.S. 557, 720 , 126 S.Ct. 2749, 2847 , 165 L.Ed. 2d 723, 832 (2006) (quoting Texas v. United States, 523 U.S. 296, 300 , 118 S.Ct. 1257, 1259 , 140 L.Ed. 2d 406, 411 (1998)) (internal quotation 1117 marks omitted and alteration in original). "[R]ipeness is peculiarly a question of timing." Anderson v. Green, 513 U.S. 557, 559 , 115 S.Ct. 1059, 1060 , 130 L.Ed. 2d 1050, 1053 (1995) (quoting Reg'l Rail Reorganization Act	1	1
Williamson County Regional Planning Commission v. Hamilton Bank of Johnson Cityred scotus · 1985 · cited in 1 New Jersey opinions naming this issue, 1996–1996 2 sentences 1996In Williamson Planning Comm’n v. Hamilton Bank, 473 U.S. 172, 195 , 105 S.Ct. 3108, 3121 , 87 L.Ed.2d 126, 144 (1985), the Court stated, “The recognition that a property owner has not suffered a violation of the Just Compensation Clause until the owner has unsuccessfully attempted to obtain just compensation through the procedures provided by the State for obtaining such compensation is analogous to the Court’s holding in Parratt.” Unlike other constitutional violations that are complete at the moment they occur, a deprivation of property without procedural due process does not arise until the 1996In Williamson Planning Comm’n v. Hamilton Bank, 473 U.S. 172, 195 , 105 S.Ct. 3108, 3121 , 87 L.Ed.2d 126, 144 (1985), the Court stated, “The recognition that a property owner has not suffered a violation of the Just Compensation Clause until the owner has unsuccessfully attempted to obtain just compensation through the procedures provided by the State for obtaining such compensation is analogous to the Court’s holding in Parratt.” Unlike other constitutional violations that are complete at the moment they occur, a deprivation of property without procedural due process does not arise until the	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway.

Also cited on this issue (4)

Case	Cited	Years
41 MAPLE ASSOC. v. Common Council green njsuperctappdiv · 1994 2 sentences 2011We stated in 41 Maple Associates, supra, that the ripeness principle “also defeats both of plaintiffs’ substantive claims: their claim for inverse condemnation ... and their claim for deprivation of their civil rights under 42 U.S.C.A. § 1983 .” 276 N.J.Super. at 619 , 648 A.2d 732 (emphasis added). 2011We stated in 41 Maple Associates, supra, that the ripeness principle “also defeats both of plaintiffs’ substantive claims: their claim for inverse condemnation ... and their claim for deprivation of their civil rights under 42 U.S.C.A. § 1983 .” 276 N.J.Super. at 619 , 648 A.2d 732 (emphasis added).	1	2011–2011
Slawek v. Gateway Broadcasting Corp. green scotus · 1993 2 sentences 2005See Murphy v. New Milford Zoning Comm'n, 402 F. 3d 342 , 347, 353-54 (2d Cir.2005) (concluding that the plaintiff's RLUIPA claim was not ripe and noting 1226 that "the ripeness doctrine's `basic rationale is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements'") (quoting Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99, 105 , 97 S.Ct. 980, 984 , 51 L.Ed. 2d 192 (1977)); Taylor Inv., Ltd. v. Upper Darby Tp., 983 F. 2d 1285 , 2005See Murphy v. New Milford Zoning Comm'n, 402 F. 3d 342 , 347, 353-54 (2d Cir.2005) (concluding that the plaintiff's RLUIPA claim was not ripe and noting 1226 that "the ripeness doctrine's `basic rationale is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements'") (quoting Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99, 105 , 97 S.Ct. 980, 984 , 51 L.Ed. 2d 192 (1977)); Taylor Inv., Ltd. v. Upper Darby Tp., 983 F. 2d 1285 ,	1	2005–2005
Employers Insurance of Wausau v. Celotex Corp green scotus · 1993 1 sentence 2005See Murphy v. New Milford Zoning Comm'n, 402 F. 3d 342 , 347, 353-54 (2d Cir.2005) (concluding that the plaintiff's RLUIPA claim was not ripe and noting *1226 that "the ripeness doctrine's `basic rationale is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements'") (quoting Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99, 105 , 97 S.Ct. 980, 984 , 51 L.Ed. 2d 192 (1977)); Taylor Inv., Ltd. v. Upper Darby Tp., 983 F. 2d 1285 ,	1	2005–2005
Taylor Investment, Ltd. v. Upper Darby Township green ca3 · 1993 1 sentence 2005See Murphy v. New Milford Zoning Comm'n, 402 F. 3d 342 , 347, 353-54 (2d Cir.2005) (concluding that the plaintiff's RLUIPA claim was not ripe and noting *1226 that "the ripeness doctrine's `basic rationale is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements'") (quoting Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507, 1515 , 18 L.Ed. 2d 681 (1967), overruled on other grounds, Califano v. Sanders, 430 U.S. 99, 105 , 97 S.Ct. 980, 984 , 51 L.Ed. 2d 192 (1977)); Taylor Inv., Ltd. v. Upper Darby Tp., 983 F. 2d 1285 ,	1	2005–2005

Where else courts name it

TX 218 (1991–2026) CA 127 (1985–2026) OH 76 (1998–2025) CT 50 (1989–2026) IL 50 (1976–2026) PA 40 (1994–2023) MI 26 (1990–2026) WA 25 (1987–2026) IA 24 (1996–2026) NM 22 (1991–2022) ID 22 (2002–2024) DE 21 (1989–2026) TN 18 (1999–2026) KY 14 (1995–2024) UT 14 (1999–2025) AZ 13 (1984–2025) OR 13 (1993–2019) MD 12 (1996–2023) WY 12 (1983–2017) MT 12 (2001–2024) AK 11 (1989–2023) ME 11 (1982–2022) NY 11 (1986–2025) MO 9 (1989–2021) IN 9 (2000–2024) NH 9 (1998–2024) HI 8 (2001–2025) FL 8 (1995–2025) NJ 7 (1996–2026) WI 7 (1994–2021) DC 6 (1981–2008) AL 6 (2008–2025) CO 6 (2003–2010) LA 6 (1995–2013) NE 5 (1994–2020) VI 5 (2002–2014) MA 4 (1994–2021) KS 4 (2008–2015) MS 2 (2015–2015) MN 2 (2016–2023) RI 2 (2000–2008) NC 2 (1993–2026)

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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