New Jersey Statutes
N.J. Stat. § 56:8-2.13 (2026)
Cumulation of rights and remedies; construction of act
✓ current as of May 2026
The rights, remedies and prohibitions accorded by the provisions of this act are hereby declared to be in addition to and cumulative of any other right, remedy or prohibition accorded by the common law or statutes of this State, and nothing contained herein shall be construed to deny, abrogate or impair any such common law or statutory right, remedy or prohibition.
Notes of Decisions
Cited in 17
cases (8 in the last 5 years), 1997–2025 · leading case: Francis E. Parker Mem'l Home, Inc. v. Georgia-Pac. LLC, 945 F. Supp. 2d 543 (D.N.J. 2013).
Francis E. Parker Mem'l Home, Inc. v. Georgia-Pac. LLC, 945 F. Supp. 2d 543 (D.N.J. 2013). “” N.J.S.A. § 56:8-2.13. While economic losses due to harm to the product itself are recoverable under the CFA, the PLA explicitly exempts such losses in its definition of harm, which allows for “physical damage to property, other than to the product itself.”
Lemelledo v. Beneficial Mgmt. Corp. of Am., 696 A.2d 546 (N.J. 1997). “In determining whether the existence of other regulations creates an exemption to the CFA for particular conduct that otherwise would fall within its provisions, it should ordinarily be assumed that the CFA applies to the covered practice. That assumption is appropriate because…”
Manor Care Inc. v. Tom Douglas, 763 S.E.2d 73 (W. Va. 2014). “in addition to” statutory language permits recovery of duplicative damages: We recognize that N.J.S.A. 56:8-2.13 enacted by P.L.1979, c.”
Yourman by & Through Yourman v. People's Sec. Life Ins. Co., 992 F. Supp. 696 (D.N.J. 1998). “The Court observed that the *702 CFA was specifically drafted to be cumulative to other legal remedies, N.J.SA. 56:8-2.13, and that the statute, by providing for private causes of action, “contemplates that consumers will act as ‘private attorneys general.”
Jodi Shaw Vs. Brian Shand (l-0408-16, Sussex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “" N.J.S.A. 56:8-2.13. The Attorney General argues that as the Supreme Court held in Lemelledo, another statutory scheme will displace the CFA only when "a direct and unavoidable conflict exists between the application of the CFA and application of the other regulatory scheme or…”
Sun Chem. Corp. v. Fike Corp. (082815)(Statewide) (N.J. 2020). “” N.J.S.A. 56:8-2.13. (pp. 18-20) 4. Said differently, if a claim is based on deceptive, fraudulent, misleading, and other unconscionable commercial practices, it is not covered by the PLA and may be brought as a separate CFA claim.”
William DeSimone v. Springpoint Senior Living, Inc (N.J. 2024). “Plaintiffs contend that, in those cases, this Court held that the phrase “this act” referred to the CFA generally when construing the cumulative remedies provision found in Section Five of Chapter 347, codified at N.J.S.A. 56:8-2.13. Plaintiffs also assert that Lemelledo,…”
William DeSimone v. Springpoint Senior Living, Inc (N.J. 2024). “Plaintiffs contend that, in those cases, this Court held that the phrase “this act” referred to the CFA generally when construing the cumulative remedies provision found in Section Five of Chapter 347, codified at N.J.S.A. 56:8-2.13. Plaintiffs also assert that Lemelledo,…”
Eubanks v. Ridgeline Motors LLC (D.N.J. 2022). “The CFA provides that the remedies under its provisions are “declared to be in addition to and cumulative of any other right, remedy or prohibition accorded by the common law or statutes of this State, and nothing contained herein shall be construed to deny, abrogate or impair…”
Twin Capital Partners, LLC v. Wickstrom (D.N.J. 2023). “(Wickstrom’s TCP Opp’n Br. 16.) Wickstrom argues that the CFA provides that its protections are intended to be cumulative to other rights in law or in equity.”
Keona Palmer v. Flagship Resort Dev. Corp., Etc. (N.J. Super. Ct. App. Div. 2025). “] N.J.S.A. 56:8-2.13 states that the CFA is intended to supplement other remedial legislation: The rights, remedies and prohibitions accorded by the provisions of this act are hereby declared to be in addition to and cumulative of any other right, remedy or prohibition accorded…”
Michael Bandler Vs. Landry's Inc., Golden Nugget Atl. City (l-0026-16, Atl. Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2020). “at 264 (quoting N.J.S.A. 56:8-2.13). On the other hand, the CCA provides that if any provision "is inconsistent with, in conflict with, or contrary to any provision of law, such provision of A-5064-17T3 8 [the CCA] shall prevail .”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.