three elements doctrine (New Jersey) · Go Syfert
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three elements doctrine in New Jersey

6 New Jersey opinions name it 1 courts 2017–2026 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 (5)

CaseFollowedCited
Bornstein v. Metropolitan Bottling Co., Inc.green
nj · 1958 · cited in 3 New Jersey opinions naming this issue, 2017–2024
2 sentences

2024This theory allows a finder of fact to infer the defendant's lack of due care only when the three elements of the doctrine have been satisfied: "(a) the occurrence itself ordinarily bespeaks negligence; (b) the instrumentality was within the defendant's exclusive control; and (c) there is no indication in the circumstances that the injury was the result of the plaintiff's own voluntary act or neglect." Ibid. (quoting Bornstein v. Metropolitan Bottling Co., 26 N.J. 263, 269 , (1958)).

2024A-1930-22 6 To satisfy res ipsa loquitur, then, plaintiffs would need to demonstrate that an 89-year-old falling while being assisted by a caregiver "itself ordinarily bespeaks negligence"; the environment was within "defendant's exclusive control"; and "there is no indication in the circumstances that the injury was the result of [Alice's] own voluntary act or neglect." See ibid.

23
In Re Kozlovgreen
nj · 1979 · cited in 1 New Jersey opinions naming this issue, 2026–2026
1 sentence

2026In its amplification, the court concluded defendant had "provided ample support for piercing the victim's patient[-]physician privilege." The court found defendant had established the three elements of the privilege-piercing test articulated by the Court in In re Kozlov, 79 N.J. 232, 243-44 (1979).

11
State v. Hollandgreen
nj · 2003 · cited in 1 New Jersey opinions naming this issue, 2020–2020
2 sentences

2020Citing State v. Holland, 176 N.J. 344, 354 (2003), the judge explained the doctrine may be invoked if "the State can prove that incriminating evidence was seized lawfully" even though "an earlier constitutional violation had occurred." The judge summarized his understanding of the three elements of the doctrine, recognized by our Supreme Court in Holland: "(1) the State had probable cause to conduct the search at issue absent the unlawfully-obtained information; (2) the State, 'without the tainted knowledge or evidence,' would have sought a proper warrant; and (3) the initial impermissible sea

2020Citing State v. Holland, 176 N.J. 344, 354 (2003), the judge explained the doctrine may be invoked if "the State can prove that incriminating evidence was seized lawfully" even though "an earlier constitutional violation had occurred." The judge summarized his understanding of the three elements of the doctrine, recognized by our Supreme Court in Holland: "(1) the State had probable cause to conduct the search at issue absent the unlawfully-obtained information; (2) the State, 'without the tainted knowledge or evidence,' would have sought a proper warrant; and (3) the initial impermissible sea

11
State v. Earlsgreen
nj · 2013 · cited in 1 New Jersey opinions naming this issue, 2018–2018
1 sentence

2018See id. at 206-08 (setting forth the three elements); see also State v. Earls, 214 N.J. 564, 592 (2013).

11
State v. Johnsongreen
nj · 2002 · cited in 1 New Jersey opinions naming this issue, 2018–2018
1 sentence

2018See id. at 206-08 (setting forth the three elements); see also State v. Earls, 214 N.J. 564, 592 (2013).

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
Meny v. Carlson green
nj · 1950
1 sentence

2024It allows a finder of fact to infer the defendant's lack of due care only when the three elements of the doctrine have been satisfied: "'(a) the occurrence itself ordinarily bespeaks negligence; (b) the instrumentality was within the defendant's exclusive control; and (c) there is no indication in the circumstances that the injury was the result of the plaintiff's own voluntary act or neglect.'" Ibid. (quoting Bornstein v. Metro.

12024–2024
TIERNEY BY TIERNEY v. St. Michael's Medical Center green
njsuperctappdiv · 1986
1 sentence

2024This theory allows a finder of fact to infer the defendant's lack of due care only when the three elements of the doctrine have been satisfied: "(a) the occurrence itself ordinarily bespeaks negligence; (b) the instrumentality was within the defendant's exclusive control; and (c) there is no indication in the circumstances that the injury was the result of the plaintiff's own voluntary act or neglect." Ibid. (quoting Bornstein v. Metropolitan Bottling Co., 26 N.J. 263, 269 , (1958)).

12024–2024
State v. Ortense green
njsuperctappdiv · 1980
1 sentence

2020Applying that test, the motion judge found "the State had probable cause to conduct the search absent the unlawful entry and tainted observation of the silver handgun and [drugs] on the dresser." Citing our decision in State v. A-4110-17T2 7 Ortense, 174 N.J.

12020–2020

Where else courts name it

CA 12 (2009–2025) MA 6 (2004–2025) PA 6 (1992–2026) NJ 6 (2017–2026) IL 5 (2014–2024) WY 5 (2004–2023) NY 4 (1898–2017) WI 4 (1987–2019) ME 3 (2001–2015) OK 3 (2013–2014) AK 3 (1998–2007) WA 3 (1973–1997) OH 3 (2006–2010) OR 3 (2003–2021) TX 3 (2000–2025) CO 2 (2005–2005) CT 2 (1988–2015) KY 2 (2013–2021) NM 2 (1986–1998) NE 2 (1993–2025) ID 2 (2002–2011)

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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