purposes doctrine in New Jersey

2003Id. at 368 , 608 A.2d [at 250], Another consideration is whether retroactive application will advance the purposes of the rule announced in the decision.

2003Id. at 370 , 608 A.2d at [, 251].

2022Indeed, our Supreme Court determined in Tevis v. Tevis, 79 N.J. 422 (1979), that "marital torts, as a class, are to be considered as related to, not 'independent' of, divorce suits" for the purposes of the doctrine.

2022Ibid. (citation omitted).

2019The purposes of the doctrine are "(1) the need for complete and final disposition through the avoidance of piecemeal decisions; (2) fairness to parties to the action and those with a material interest in the action; and (3) efficiency and the avoidance of waste and the reduction of delay." Ibid. (quoting DiTrolio v. Antiles, 142 N.J. 253, 267 (1995)).

2017The purposes of the doctrine are "'(1) the need for complete and final disposition through the avoidance of piecemeal decisions; (2) fairness to parties to the action and those with a material interest in the action; and (3) efficiency and the avoidance of waste and the reduction of delay.'" Wadeer, supra, 220 N.J. at 605 (quoting DiTrolio v. Antiles, 142 N.J. 253, 267 (1995)).

2026Thus "[t]he rule gives rise to a rebuttable inference that the defendant is negligent, and obviates A-2305-24 11 the need for the plaintiff to prove actual or constructive notice." Prioleau, 223 N.J. at 258 . [Jeter, 250 N.J. at 252 (second citation reformatted).] For the purposes of our analysis, we initially note that a large accumulation of water located within the aisle of a supermarket, where customers constantly traverse, is a dangerous condition. 3 The Court has long applied the mode-of-operation rule in self-service settings.

2026See Jeter, 250 N.J. 240 (2022); Prioleau, 223 N.J. 245 (2015); Nisivoccia, 175 N.J. 559 (2003); Wollerman, 47 N.J. 426 (1966); Troupe, 443 N.J.

2026See Jeter, 250 N.J. 240 (2022); Prioleau, 223 N.J. 245 (2015); Nisivoccia, 175 N.J. 559 (2003); Wollerman, 47 N.J. 426 (1966); Troupe, 443 N.J.

2026See Jeter, 250 N.J. 240 (2022); Prioleau, 223 N.J. 245 (2015); Nisivoccia, 175 N.J. 559 (2003); Wollerman, 47 N.J. 426 (1966); Troupe, 443 N.J.

2026See Jeter, 250 N.J. 240 (2022); Prioleau, 223 N.J. 245 (2015); Nisivoccia, 175 N.J. 559 (2003); Wollerman, 47 N.J. 426 (1966); Troupe, 443 N.J.

2020A-2066-18T1 8 requires a showing that "counsel's representation fell below an objective standard of reasonableness." Strickland, 466 U.S. at 688 .

2012Nix v. Williams, supra, 467 U.S. at 443 , 104 S.Ct. at 2508 , 81 L.Ed.2d at 387 .

2012Nix v. Williams, supra, 467 U.S. at 443 , 104 S.Ct. at 2508 , 81 L.Ed.2d at 387 .

2009To establish a claim for a hostile work environment, plaintiff must prove that the conduct "(1) would not have occurred but for the employee's protected status, and was (2) severe or pervasive enough to make a(3) reasonable person believe that (4) the conditions of employment have been altered and that the working environment is hostile or abusive." Shepherd v. Hunterdon Developmental Ctr., supra, 174 N.J. at 24 , 803 A. 2d 611 (citing Lehmann v. Toys `R' Us, Inc., 132 N.J. 587, 603-04 , 626 A. 2d 445 (1993)).

2009To establish a claim for a hostile work environment, plaintiff must prove that the conduct "(1) would not have occurred but for the employee's protected status, and was (2) severe or pervasive enough to make a(3) reasonable person believe that (4) the conditions of employment have been altered and that the working environment is hostile or abusive." Shepherd v. Hunterdon Developmental Ctr., supra, 174 N.J. at 24 , 803 A. 2d 611 (citing Lehmann v. Toys `R' Us, Inc., 132 N.J. 587, 603-04 , 626 A. 2d 445 (1993)).

2009To establish a claim for a hostile work environment, plaintiff must prove that the conduct "(1) would not have occurred but for the employee's protected status, and was (2) severe or pervasive enough to make a(3) reasonable person believe that (4) the conditions of employment have been altered and that the working environment is hostile or abusive." Shepherd v. Hunterdon Developmental Ctr., supra, 174 N.J. at 24 , 803 A. 2d 611 (citing Lehmann v. Toys `R' Us, Inc., 132 N.J. 587, 603-04 , 626 A. 2d 445 (1993)).

2009To establish a claim for a hostile work environment, plaintiff must prove that the conduct "(1) would not have occurred but for the employee's protected status, and was (2) severe or pervasive enough to make a(3) reasonable person believe that (4) the conditions of employment have been altered and that the working environment is hostile or abusive." Shepherd v. Hunterdon Developmental Ctr., supra, 174 N.J. at 24 , 803 A. 2d 611 (citing Lehmann v. Toys `R' Us, Inc., 132 N.J. 587, 603-04 , 626 A. 2d 445 (1993)).

2006See White, supra, 76 N.J. at 380-81 , 388 A. 2d 206 ; Borough of Park Ridge v. Salimone, 21 N.J. 28, 45-49 , 120 A. 2d 721 (1956).

2006See White, supra, 76 N.J. at 380-81 , 388 A. 2d 206 ; Borough of Park Ridge v. Salimone, 21 N.J. 28, 45-49 , 120 A. 2d 721 (1956).

2005Distribution to the press and public of pleadings and other documents *288 may be a tactic chosen by litigators, but it is not immunized as a part of the judicial process. [ Citizens State Bank of N.J., 215 N.J.Super. at 199 , 521 A. 2d 867 .] Communications made to newspapers and during press conferences "have been almost universally found to be excluded from the protection of absolute privilege." DeVivo, 228 N.J.Super. at 462 , 550 A. 2d 163 (citing Asay v. Hallmark Cards, 594 F. 2d 692, 698 (8th Cir.1979)).

2005Distribution to the press and public of pleadings and other documents *288 may be a tactic chosen by litigators, but it is not immunized as a part of the judicial process. [ Citizens State Bank of N.J., 215 N.J.Super. at 199 , 521 A. 2d 867 .] Communications made to newspapers and during press conferences "have been almost universally found to be excluded from the protection of absolute privilege." DeVivo, 228 N.J.Super. at 462 , 550 A. 2d 163 (citing Asay v. Hallmark Cards, 594 F. 2d 692, 698 (8th Cir.1979)).

2005Distribution to the press and public of pleadings and other documents *288 may be a tactic chosen by litigators, but it is not immunized as a part of the judicial process. [ Citizens State Bank of N.J., 215 N.J.Super. at 199 , 521 A. 2d 867 .] Communications made to newspapers and during press conferences "have been almost universally found to be excluded from the protection of absolute privilege." DeVivo, 228 N.J.Super. at 462 , 550 A. 2d 163 (citing Asay v. Hallmark Cards, 594 F. 2d 692, 698 (8th Cir.1979)).

2005Distribution to the press and public of pleadings and other documents *288 may be a tactic chosen by litigators, but it is not immunized as a part of the judicial process. [ Citizens State Bank of N.J., 215 N.J.Super. at 199 , 521 A. 2d 867 .] Communications made to newspapers and during press conferences "have been almost universally found to be excluded from the protection of absolute privilege." DeVivo, 228 N.J.Super. at 462 , 550 A. 2d 163 (citing Asay v. Hallmark Cards, 594 F. 2d 692, 698 (8th Cir.1979)).

2000State v. Bilancio, supra, 318 N.J.Super. at 417-18 , 724 A. 2d 278 ; LaFave, supra, § 4.8(a).

2000State v. Bilancio, supra, 318 N.J.Super. at 417-18 , 724 A. 2d 278 ; LaFave, supra, § 4.8(a).

2000Ibid.

1998It is a fundamental objective of this procedural reform to avoid the delays and wasteful expense of the multiplicity of litigation which results from splitting of a controversy. [ Ajamian v. Schlanger, 14 N.J. 483, 485 , 103 A. 2d 9 , cert. denied, 348 U.S. 835 , 75 S.Ct. 58 , 99 L.Ed. 659 (1954).] In Cogdell v. Hospital Center at Orange, 116 N.J. 7, 15 , 560 A. 2d 1169 (1989) (citing 2 State of New Jersey Constitutional Convention of 1947, Committee on the Judiciary Report § 11(J) at 1187 (1947)), we observed that "the purposes of the doctrine include the needs of economy and the avoidance of

1998It is a fundamental objective of this procedural reform to avoid the delays and wasteful expense of the multiplicity of litigation which results from splitting of a controversy. [ Ajamian v. Schlanger, 14 N.J. 483, 485 , 103 A. 2d 9 , cert. denied, 348 U.S. 835 , 75 S.Ct. 58 , 99 L.Ed. 659 (1954).] In Cogdell v. Hospital Center at Orange, 116 N.J. 7, 15 , 560 A. 2d 1169 (1989) (citing 2 State of New Jersey Constitutional Convention of 1947, Committee on the Judiciary Report § 11(J) at 1187 (1947)), we observed that "the purposes of the doctrine include the needs of economy and the avoidance of

1998It is a fundamental objective of this procedural reform to avoid the delays and wasteful expense of the multiplicity of litigation which results from splitting of a controversy. [ Ajamian v. Schlanger, 14 N.J. 483, 485 , 103 A. 2d 9 , cert. denied, 348 U.S. 835 , 75 S.Ct. 58 , 99 L.Ed. 659 (1954).] In Cogdell v. Hospital Center at Orange, 116 N.J. 7, 15 , 560 A. 2d 1169 (1989) (citing 2 State of New Jersey Constitutional Convention of 1947, Committee on the Judiciary Report § 11(J) at 1187 (1947)), we observed that "the purposes of the doctrine include the needs of economy and the avoidance of

1998It is a fundamental objective of this procedural reform to avoid the delays and wasteful expense of the multiplicity of litigation which results from splitting of a controversy. [Ajamian v. Schlanger, 14 N.J. 483, 485 , 103 A.2d 9 , cert. denied, 348 U.S. 835 , 75 S.Ct. 58 , 99 L.Ed. 659 (1954).] In Cogdell v. Hospital Center at Orange, 116 N.J. 7, 15 , 560 A.2d 1169 (1989) (citing 2 State of New Jersey Constitutional Convention of 1947, Committee on the Judiciary Report § 11(J) at 1187 (1947)), we observed that “the purposes of the doctrine include the needs of economy and the avoidance of wa

1998Cogdell v. Hospital Center at Orange, 116 N.J. 7, 15 , 560 A. 2d 1169 (1989); see also Thornton v. Potamkin Chevrolet, 94 N.J. 1, 8 , 462 A. 2d 133 (1983) (explaining that fractionalized claims are detrimental to our judicial system); Applestein v. United Board & Carton Corp., 35 N.J. 343, 356 , 173 A. 2d 225 (1961) (stating that "[t]he sound administration of a judicial system requires that all facets of a single dispute between parties be completely determined in one action").

1998Cogdell v. Hospital Center at Orange, 116 N.J. 7, 15 , 560 A. 2d 1169 (1989); see also Thornton v. Potamkin Chevrolet, 94 N.J. 1, 8 , 462 A. 2d 133 (1983) (explaining that fractionalized claims are detrimental to our judicial system); Applestein v. United Board & Carton Corp., 35 N.J. 343, 356 , 173 A. 2d 225 (1961) (stating that "[t]he sound administration of a judicial system requires that all facets of a single dispute between parties be completely determined in one action").