Court: Supreme Court of New Jersey
Opinion Date: July 15, 2021
Areas of Law: Civil Procedure, Family Law, Government & Administrative Law, Health Law, Personal Injury
The issue this case presented for the New Jersey Supreme Court’s consideration was whether, under the facts of this case, plaintiff Leah Coleman, the victim of a violent assault by social worker Sonia Martinez’s patient, could bring a negligence claim against Martinez. Martinez’s patient, T.E., suffered two violent episodes prior to her treatment with Martinez. Coleman worked for the Division of Child Protection and Permanency (DCPP) and was tasked with ensuring the welfare of T.E.’s children when the children were removed from T.E.’s care after her hospitalization following her second violent incident. In a letter to Coleman dated October 1, 2014, Martinez stated that T.E. had been compliant during her sessions and with her medication and was ready and able to begin having unsupervised visits with her children with the goal of reunification. At her deposition, Martinez acknowledged the inaccuracy of representing that T.E. did not exhibit psychotic symptoms in light of what she and the group counselor had seen. During a November 7 appointment, Martinez disclosed to T.E. Coleman’s report of T.E.’s hallucinations. T.E. “became upset” and “tearful,” denied any psychotic symptoms, and reiterated her goal of regaining custody of her children. Later that day, T.E. called DCPP and spoke with Coleman. During their conversation, T.E. referenced her session with Martinez, denied that she was experiencing auditory hallucinations, and stated she did not understand why such a claim would be fabricated. Coleman advised T.E. to seek advice from an attorney as DCPP would “maintain that she [was] not capable of parenting independently due to her mental health issues.” Six days later, T.E. made an unscheduled visit to DCPP offices, where she stabbed Coleman twenty-two times in the face, chest, arms, shoulders, and back. Coleman filed a complaint against Martinez, alleging that Martinez was negligent in identifying her to T.E. as the source of information about T.E.’s hallucinations, and that T.E.’s attack was a direct and proximate result of Martinez’s negligence. The trial court granted summary judgment in favor of Martinez, finding no legal duty owed to Coleman under the particularized foreseeability standard set forth in J.S. v. R.T.H., 155 N.J. 330 (1998). The Supreme Court disagreed, finding that Martinez had a duty to Coleman under the circumstances here. The trial court’s judgment was reversed and the matter remanded for further proceedings.
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