Allstate New Jersey Ins. Co. v. Gregorio Lajara (073511)
117 A.3d 1221
| N.J. | 2015Background
- Private IFPA action by Allstate entities against 63 defendants alleging an $8.14M fraud scheme to recover PI benefits; sought compensatory damages, treble damages, attorneys’ fees, disgorgement, and equitable relief; jury demand withdrawn; trial court and Appellate Division denied jury trial under Sailor framework.
- IFPA remedies are monetary (compensatory and treble damages) and fees; treble damages function as punitive-like relief; IFPA does not expressly provide for a jury trial.
- Appellate Division relied on Sailor to hold no jury trial right in private IFPA actions; panel deemed IFPA remedies akin to restitution/equitable relief.
- Court clarifies historical jury-trial right is a fundamental civil right; determines IFPA damages are legal, not equitable, and relate to common-law fraud; right to jury trial implied in IFPA and Constitution.
- Remands to Law Division to permit jury on issues within its domain while reserving equitable relief determinations for the court.
- Court historically treats IFPA as aligned with CFA and common-law fraud for purposes of jury trial right; private actions predominate in legal claims over equitable remedies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there a right to a civil jury trial for private IFPA actions? | Allstate asserted no jury right; IFPA remedies are equitable and statute silent on jury trials. | Lajara/Patel argued IFPA remedies are legal and akin to common-law fraud; jury trial implied. | Yes; Article I, P9 provides jury trial right; IFPA remedies are legal and akin to common-law fraud; remand for jury trial. |
Key Cases Cited
- State v. Sailor, 355 N.J. Super. 315 (App. Div. 2001) (IFPA remedies viewed as equitable; no jury right in State action seeking restitution)
- Jersey Cent. Power & Light Co. v. Melcar Util. Co., 212 N.J. 576 (2013) (Remedies’ nature controls jury-right analysis; remedy is key)
- Zorba Contractors, Inc. v. Housing Authority of Newark, 362 N.J. Super. 124 (App. Div. 2003) (Implied jury trial right under CFA where relief is legal in nature)
- Curtis v. Loether, 415 U.S. 189 (1974) (Seventh Amendment applies to legal rights; distinguishes legal vs. equitable relief)
- In re Envtl. Ins. Declaratory Judgment Actions, 149 N.J. 278 (1997) (Constitutional right to jury trial arises from statute or constitution; not universal in all civil cases)
- Wood v. N.J. Mfrs. Ins. Co., 206 N.J. 562 (2011) (Remedies and nature of relief inform jury-right analysis; money damages are legal)
- N.J. S.A. 56:8-19 (CFA analogue authority), (statute not a case, included for context) () (CFA discussed as comparative framework for jury-right analysis)