New Jersey Statutes

N.J. Stat. § 34:19-4 (2026)

Written notice required

✓ current as of May 2026
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The protection against retaliatory action provided by this act pertaining to disclosure to a public body shall not apply to an employee who makes a disclosure to a public body unless the employee has brought the activity, policy or practice in violation of a law, or a rule or regulation promulgated pursuant to law to the attention of a supervisor of the employee by written notice and has afforded the employer a reasonable opportunity to correct the activity, policy or practice. Disclosure shall not be required where the employee is reasonably certain that the activity, policy or practice is known to one or more supervisors of the employer or where the employee reasonably fears physical harm as a result of the disclosure provided, however, that the situation is emergency in nature.

Notes of Decisions
Cited in 6 cases (2 in the last 5 years), 2013–2023 · leading case: Stapleton v. DSW, Inc., 931 F. Supp. 2d 635 (D.N.J. 2013).
Stapleton v. DSW, Inc., 931 F. Supp. 2d 635 (D.N.J. 2013). · cites it 2× “N.J. Stat. Ann. § 34:19-4 (emphasis added).”
Michael Wolff v. Salem Cnty. Corr. Facility & Cnty. of Salem, 108 A.3d 636 (N.J. Super. Ct. App. Div. 2015). “Plaintiff then filed reports claiming this too was retaliation in violation of N.J.S.A. 34:19-4 of CEPA, which he called the "Whistleblower Protection Act.”
Lisa R. Easley Vs. New Jersey Dep't of Corr. (l-0094-13, Burlington Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). · cites it 4× “The notice identifies Leila Lawrence as the designated contact person to receive written notifications pursuant to N.J.S.A. 34:19-4. It also provides her telephone number.”
Mary Steinhauer-kula Vs. Millville Bd. of Educ. (l-0348-17, Cumberland Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2021). · cites it 2× “In addition, the court concluded that, even if Kula's report of the breach of PARCC protocols constituted whistleblowing, pursuant to N.J.S.A. 34:19-4, she could not allege a CEPA cause of action because BOE cured the breach after receiving notice from Kula.”
Joel S. Lippman, M.D. v. Ethicon, Inc. (073324) (N.J. 2015). · cites it 3× “Through N.J.S.A. 34:19-4, the Legislature has required prior notice to the employer and opportunity to correct the activity, policy, or practice, in order for a putative whistleblower plaintiff to obtain protection against retaliatory action for disclosure made to a public body.”
Murray v. Cnty. of Hudson (D.N.J. 2023). “To invoke this statute, the employee who intends to report alleged wrongdoing must advise a supervisor in writing and give the supervisor a reasonable opportunity to correct the problem, N.J.S.A. 34:19-4. Further, the statute provides, in relevant part, that: "Upon a violation…”
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