New Jersey Statutes

N.J. Stat. § 34:19-3 (2026)

Retaliatory action prohibited

✓ current as of May 2026
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3. An employer shall not take any retaliatory action against an employee because the employee does any of the following:

a. Discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice of the employer, or another employer, with whom there is a business relationship, that the employee reasonably believes:

(1) is in violation of a law, or a rule or regulation promulgated pursuant to law, including any violation involving deception of, or misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity, or, in the case of an employee who is a licensed or certified health care professional, reasonably believes constitutes improper quality of patient care; or

(2) is fraudulent or criminal, including any activity, policy or practice of deception or misrepresentation which the employee reasonably believes may defraud any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity;

b. Provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into any violation of law, or a rule or regulation promulgated pursuant to law by the employer, or another employer, with whom there is a business relationship, including any violation involving deception of, or misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity, or, in the case of an employee who is a licensed or certified health care professional, provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into the quality of patient care; or

c. Objects to, or refuses to participate in any activity, policy or practice which the employee reasonably believes:

(1) is in violation of a law, or a rule or regulation promulgated pursuant to law, including any violation involving deception of, or misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity, or, if the employee is a licensed or certified health care professional, constitutes improper quality of patient care;

(2) is fraudulent or criminal, including any activity, policy or practice of deception or misrepresentation which the employee reasonably believes may defraud any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity; or

(3) is incompatible with a clear mandate of public policy concerning the public health, safety or welfare or protection of the environment.

Notes of Decisions
Cited in 248 cases (111 in the last 5 years), 1988–2026 · leading case: James Hitesman v. Bridgeway, Inc. (072466), 93 A.3d 306 (N.J. 2014).
James Hitesman v. Bridgeway, Inc. (072466), 93 A.3d 306 (N.J. 2014). · cites it 70× “See N.J.S.A. 34:19-3(a); N.J.S.A. 34:19-3(c).”
Steven Trzaska v. LOreal USA Inc, 865 F.3d 155 (3rd Cir. 2017). · cites it 13× “N.J. Stat. Ann. § 34:19-3 (c).2 Accordingly, a plaintiff must identify a law, rule, regulation, or clear mandate of public policy, that supports the basis of his CEPA claim as well as “unacceptable practices in the defendant employer’s 2 Trzaska insists that N.”
Sergeant First Class Frank Chiofalo v. State of New Jersey (081607)(Mercer Cnty. & Statewide), 213 A.3d 900 (N.J. 2019). · cites it 17× “Pertinent to this appeal, 5 CEPA provides as follows: An employer shall not take any retaliatory action against an employee because the employee does any of the following: a.”
Rivera v. City of Camden Bd. of Educ., 634 F. Supp. 2d 486 (D.N.J. 2009). · cites it 15× “N.J.S.A. § 34:19-3. A plaintiff must satisfy a four-pronged test to state a prima facie case under CEPA, as follows: “(1) that he or she reasonably believed that his or her employer’s conduct was violating either a *489 law or a rule or regulation promulgated pursuant to law;…”
Ivan v. Cnty. of Middlesex, 595 F. Supp. 2d 425 (D.N.J. 2009). · cites it 3× “See N.J. Stat. Ann. § 34:19-3 (2000). “The definition of retaliatory action speaks in terms of completed action.”
Richmond Lapolla v. Cnty. of Union, 157 A.3d 458 (N.J. Super. Ct. App. Div. 2017). · cites it 2× “10:5-12(d); N.J.S.A. 34:19-3. The NJCRA authorizes a private right of action in the following provision: Any person who has been deprived of any substantive due process or equal protection rights, privileges or immunities secured by the Constitution or laws of the United States,…”
Carlino v. Gloucester City High Sch., 57 F. Supp. 2d 1 (D.N.J. 1999). · cites it 6× “, also alleges that her rights under the First Amendment and under the New Jersey Conscientious Employee Protection Act, N.J. Stat. Ann. § 34:19-3 , were violated when she lost her position as freshman field hockey coach as a result of her criticism of the high school principal…”
Fraternal Order of Police, Lodge 1 v. City of Camden, 842 F.3d 231 (3rd Cir. 2016). “NJ. Stat. Ann. § 34:19-3 (West). 22 . See Blackburn v.”
Blackburn v. United Parcel Serv., Inc., 3 F. Supp. 2d 504 (D.N.J. 1998). · cites it 5× “N.J.S.A. § 34:19-3. In order to maintain a cause of action under subsections (a), (c)(1), or (c)(2) of *513 CEPA, plaintiff must -satisfy two elements.”
Tegler v. Global Spectrum, 291 F. Supp. 3d 565 (D.N.J. 2018). · cites it 2× “The second element of the prima facie case of Tegler's CEPA claim requires that she performed a "whistle-blowing" activity as described in N.J.S.A. 34:19-3, which states: "An employer shall not take any retaliatory action against an employee because the employee does any of the…”
Matthews v. New Jersey Inst. of Tech., 772 F. Supp. 2d 647 (D.N.J. 2011). · cites it 10× “To establish a prima facie case of retaliation under CEPA, a plaintiff must show that: (1) he reasonably believed that his employer’s conduct was in violation of a law, rule, or regulation, or was contrary to a clear mandate of public policy; (2) the employee performed a…”
Schlichtig v. Inacom Corp., 271 F. Supp. 2d 597 (D.N.J. 2003). · cites it 3× “Discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice of the employer or another employer, with whom there is a business relationship, that the employee reasonably believes is in violation of a law, or a rule or regulation…”
— N.J. Stat. § 34:19-3(CEPA) — 1 case
— N.J. Stat. § 34:19-3(a) — 56 cases
James Hitesman v. Bridgeway, Inc. (072466), 93 A.3d 306 (N.J. 2014). “See N.J.S.A. 34:19-3(a); N.J.S.A. 34:19-3(c).”
Sergeant First Class Frank Chiofalo v. State of New Jersey (081607)(Mercer Cnty. & Statewide), 213 A.3d 900 (N.J. 2019). “Pertinent to this appeal, 5 CEPA provides as follows: An employer shall not take any retaliatory action against an employee because the employee does any of the following: a.”
Rivera v. City of Camden Bd. of Educ., 634 F. Supp. 2d 486 (D.N.J. 2009). “N.J.S.A. § 34:19-3. A plaintiff must satisfy a four-pronged test to state a prima facie case under CEPA, as follows: “(1) that he or she reasonably believed that his or her employer’s conduct was violating either a *489 law or a rule or regulation promulgated pursuant to law;…”
Smith v. Twp. of East Greenwich, 519 F. Supp. 2d 493 (D.N.J. 2007).
Gutierrez v. Sundancer Indian Jewelry, Inc., 868 P.2d 1266 (N.M. Ct. App. 1993).
— N.J. Stat. § 34:19-3(a)(1) — 26 cases
James Hitesman v. Bridgeway, Inc. (072466), 93 A.3d 306 (N.J. 2014). “See N.J.S.A. 34:19-3(a); N.J.S.A. 34:19-3(c).”
Tegler v. Global Spectrum, 291 F. Supp. 3d 565 (D.N.J. 2018). “The second element of the prima facie case of Tegler's CEPA claim requires that she performed a "whistle-blowing" activity as described in N.J.S.A. 34:19-3, which states: "An employer shall not take any retaliatory action against an employee because the employee does any of the…”
— N.J. Stat. § 34:19-3(a)(2) — 5 cases
Daniels, C. v. Atl. Comm Bank (Pa. Super. Ct. 2019).
— N.J. Stat. § 34:19-3(b) — 5 cases
Smith v. Travelers Mortg. Servs., 699 F. Supp. 1080 (D.N.J. 1988).
Haylee Olsen v. Zaman Pizza Inc (N.J. Super. Ct. App. Div. 2024).
— N.J. Stat. § 34:19-3(c) — 81 cases
Sergeant First Class Frank Chiofalo v. State of New Jersey (081607)(Mercer Cnty. & Statewide), 213 A.3d 900 (N.J. 2019). “Pertinent to this appeal, 5 CEPA provides as follows: An employer shall not take any retaliatory action against an employee because the employee does any of the following: a.”
James Hitesman v. Bridgeway, Inc. (072466), 93 A.3d 306 (N.J. 2014). “See N.J.S.A. 34:19-3(a); N.J.S.A. 34:19-3(c).”
Rivera v. City of Camden Bd. of Educ., 634 F. Supp. 2d 486 (D.N.J. 2009). “N.J.S.A. § 34:19-3. A plaintiff must satisfy a four-pronged test to state a prima facie case under CEPA, as follows: “(1) that he or she reasonably believed that his or her employer’s conduct was violating either a *489 law or a rule or regulation promulgated pursuant to law;…”
Davila v. City of Camden, 66 F. Supp. 3d 529 (D.N.J. 2014).
Schlichtig v. Inacom Corp., 271 F. Supp. 2d 597 (D.N.J. 2003). “Discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice of the employer or another employer, with whom there is a business relationship, that the employee reasonably believes is in violation of a law, or a rule or regulation…”
— N.J. Stat. § 34:19-3(c)(1) — 22 cases
James Hitesman v. Bridgeway, Inc. (072466), 93 A.3d 306 (N.J. 2014). “See N.J.S.A. 34:19-3(a); N.J.S.A. 34:19-3(c).”
Sergeant First Class Frank Chiofalo v. State of New Jersey (081607)(Mercer Cnty. & Statewide), 213 A.3d 900 (N.J. 2019). “Pertinent to this appeal, 5 CEPA provides as follows: An employer shall not take any retaliatory action against an employee because the employee does any of the following: a.”
Davis v. Benihana, Inc. (D.N.J. 2025).
— N.J. Stat. § 34:19-3(c)(2) — 2 cases
Sergeant First Class Frank Chiofalo v. State of New Jersey (081607)(Mercer Cnty. & Statewide), 213 A.3d 900 (N.J. 2019). “Pertinent to this appeal, 5 CEPA provides as follows: An employer shall not take any retaliatory action against an employee because the employee does any of the following: a.”
Schlichtig v. Inacom Corp., 271 F. Supp. 2d 597 (D.N.J. 2003). “Discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice of the employer or another employer, with whom there is a business relationship, that the employee reasonably believes is in violation of a law, or a rule or regulation…”
— N.J. Stat. § 34:19-3(c)(3) — 18 cases
James Hitesman v. Bridgeway, Inc. (072466), 93 A.3d 306 (N.J. 2014). “See N.J.S.A. 34:19-3(a); N.J.S.A. 34:19-3(c).”
Richmond Lapolla v. Cnty. of Union, 157 A.3d 458 (N.J. Super. Ct. App. Div. 2017). “10:5-12(d); N.J.S.A. 34:19-3. The NJCRA authorizes a private right of action in the following provision: Any person who has been deprived of any substantive due process or equal protection rights, privileges or immunities secured by the Constitution or laws of the United States,…”
Tinio v. Saint Joseph Reg'l Med. Ctr., 645 F. App'x 173 (3rd Cir. 2016).
SPENCE-PARKER v. Delaware River & Bay Auth., 656 F. Supp. 2d 488 (D.N.J. 2009).
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