New Jersey Statutes
N.J. Stat. § 59:2-4 (2026)
Adoption or failure to adopt or enforce a law
✓ current as of May 2026
A public entity is not liable for any injury caused by adopting or failing to adopt a law or by failing to enforce any law.
Notes of Decisions
Cited in 23
cases (9 in the last 5 years), 1981–2026 · leading case: Doe v. Div. of Youth & Fam. Servs., 148 F. Supp. 2d 462 (D.N.J. 2001).
Doe v. Div. of Youth & Fam. Servs., 148 F. Supp. 2d 462 (D.N.J. 2001). “” N.J. Stat. Ann. § 59:2-4 . In Count IX of the complaint, the plaintiffs are attempting to do nothing more than impose liability on the State Defendants for allegedly failing to enforce state law requiring an investigation of abuse and neglect complaints.”
L.E. & P.T. Vs. the Plainfield Pub. Sch. Dist. Vs. A.D. & R.B. (l-2513-15, Union Cnty. & Statewide) (record Impounded), 194 A.3d 105 (N.J. Super. Ct. App. Div. 2018). “" See also N.J.S.A. 59:2-4 (extending similar immunity to public entities).”
Rudolph v. Adamar of New Jersey, Inc., 153 F. Supp. 2d 528 (D.N.J. 2001). “Pursuant to the terms of N.J.S.A. § 59:2-4, “[a] public entity is not hable for any injury caused by adopting or failing to adopt a law or failing to enforce any law.”
Bros. v. Highlands, 428 A.2d 528 (N.J. Super. Ct. App. Div. 1981). “*150 So with respect now to Section 59:2-4 which would be applicable, it says, "A public entity is not liable for an injury caused by adopting or failing to adopt a law or by failing to enforce any law.”
United States v. Rohm & Haas Co., 939 F. Supp. 1157 (D.N.J. 1996). “Additionally, N.J.S.A. 59:2-4 provides NJDEP with immunity for failing to enforce any law.”
K.J. ex rel. Lowry v. Div. of Youth & Fam. Servs., 363 F. Supp. 2d 728 (D.N.J. 2005). “§ 59:2-4 (1992). See also Cadmus v. Long Branch Bd.”
Kj Ex Rel. Lowry v. Div. of Youth & Fam., 363 F. Supp. 2d 728 (D.N.J. 2005). “§ 59:2-4 (1992). See also Cadmus v. Long Branch Bd.”
Trussell v. Monmouth Cnty. (D.N.J. 2025). “The County Defendants also rely on N.J. Stat. Ann. § 59:2-4 (“A public entity is not liable for any injury caused by adopting or failing to enforce a law.”
Daniel Mattos Vs. Pvt. Peter S. Hotalen - Am. Legion Post 157 (l-0328-14, Sussex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2018). “The DOT moved for summary judgment before the Law Division, arguing it was immune from liability under N.J.S.A. 59:2-4 of the TCA, which provides: "A public entity is not liable for any injury caused by adopting or failing to adopt a law or by failing to enforce any law.”
Anasia Maison v. NJ Transit Corp. & Kelvin Coats (083484) (Essex Cnty. & Statewide) (N.J. 2021). “Nor are defendants immune from liability on the basis that they failed to enforce a law under N.J.S.A. 59:2-4 (public entity) and N.J.S.”
Est. of Hiram A. Gonzalez v. The City of Jersey City (084381) (Hudson Cnty. & Statewide) (N.J. 2021). “The Court explains why other sections of the TCA cited by defendants in asserting immunity from liability -- N.J.S.A. 59:2-4 and :3-5 (failure to enforce a law), :3-3 (good faith enforcement of a law), :5-5 (failure to make an arrest), and :5-4 (failure to provide police…”
Jennifer Buddy Vs. Jonathan E. Knapp Corrine Buddy Vs. Jonathan E. Knapp Damien Conneen Vs. State of New Jersey (l-1037-16, L-1046-16, & L-1049-16, Atl. Cnty. & Statewide) (Consol.) (N.J. Super. Ct. App. Div. 2021). “The State argued it was entitled to immunity for all claims asserted against it under three provisions of the TCA: (1) law enforcement immunity, N.J.S.A. 59:2-4, for an alleged failure to enforce its regulations; (2) licensing immunity, N.”
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