CLEARY GIACOBBE ALFIERI JACOBS OBTAINS DISMISSAL OF RETIREE HEALTH BENEFITS CLAIMS AGAINST COUNTY OF MORRIS IN ITS ENTIRETY WITH PREJUDICE

On July 31, 2025, the Honorable Jodi Lee Alper, J.S.C., in the Superior Court of New Jersey, Chancery Division, Morris County, issued an opinion in Michael Peoples v. County of Morris, et al, dismissing the Plaintiff’s Complaint against the County of Morris in its entirety, with prejudice. The Plaintiff’s Complaint consisted of six counts, wherein the Plaintiff had alleged that he was improperly denied retiree health benefits from the County based upon the County’s retiree health benefit program.

The firm represented the County of Morris, the administrator of the retiree health benefits at issue. The County of Morris offers retiree health benefits to employees who meet certain statutorily set qualifications and retire with the County after meeting those qualifications. The Plaintiff did not, and could not, retire with the County of Morris at the time of his voluntary termination of employment with the County, and instead accepted subsequent public employment with the Township of Long Hill. As such, the Plaintiff was not entitled to the retiree health benefits as alleged in his Complaint. Our firm filed a motion to dismiss in March of 2025, seeking the dismissal of Plaintiff’s Complaint in its entirety, with prejudice.

The Court agreed with the firm’s arguments regarding Plaintiff’s entitlement to retiree health benefits paid by the County of Morris. Specifically, the Court agreed with the firm’s argument that Plaintiff did not, and could not, retire as a matter of New Jersey law governing public employment. Accordingly, the Court found that the Plaintiff was not entitled to the retiree health benefits at issue under any of Plaintiff’s stated causes of action. The Court further agreed with the firm’s position on multiple estoppel-based claims and the Plaintiff’s allegations of County interference with alternative employment prospects, highlighting the Plaintiff’s failure to retire as was required by the County as one of several fatal flaws in the Plaintiff’s Complaint, along with Plaintiff’s failure to plead sufficient facts to support his allegations against the County.

Matthew J. Giacobbe, Partner of the Firm, John A. Napolitano, Partner of the Firm, and Kyle C. McLester, Associate of the Firm, briefed and handled the case representing the County of Morris from its inception. 

On July 22, 2025, the Honorable Zahid N. Quraishi, U.S.D.J., in the United States District Court for the District of New Jersey, issued an opinion in Carolyn Peterson-Daily v. City of Asbury Park, et al., dismissing the Plaintiff’s claim against the City and its Municipal Court Officials for alleged violations of the Plaintiff’s Sixth and Fourteenth Amendment Constitutional rights and 42 U.S.C. § 1983. The Court dismissed the Plaintiff’s Complaint based on the well-established immunities afforded to judges, prosecutors, and court officials for judicial acts.

The firm represented the City, as well as the City’s Municipal Court Judge, Administrator, and Prosecutor, with regard to the Plaintiff’s Complaint in which she alleged that the Municipal Court violated her rights by staying her criminal case pending the outcome of her state civil matter. Our firm filed a motion to dismiss in October 2024, seeking a judgment on the pleadings that the Plaintiff’s Complaint failed to state a valid cause of action due to the immunities afforded to judicial officials.

The Court agreed with the firm’s arguments that the Municipal Judge’s determination to stay the case was protected by the Judge’s absolute immunity. The Court found that the decision to stay a case is well within the authority of a court to manage its docket and is a measure performed by a judge in his or her official capacity. The Court noted the importance of judicial immunity, stating that it “serves to prevent judicial officers from being chilled by the constant threat of civil rights lawsuits for making controversial decisions.”

Judge Quraishi also determined that the Court Administrator was immune from suit due to the quasi-judicial immunity afforded to court officials, since scheduling cases is integral to the judicial process and the Court Administrator was following direction from the Judge and Prosecutor. The Court also determined that the Prosecutor was immune from suit since deferring the prosecution of Plaintiff’s criminal case was within the judicial phase of the criminal process to which immunity applies. Finally, the Court agreed that the City could not be liable, since the municipal body possesses no legal control over the judicial function of its municipal court.

Anthony P. Seijas, Partner of the Firm, and Gregory A. Randazzo, Counsel of the Firm, briefed and handled the case representing the City of Asbury Park and its Court Officials from its inception.