BAYONNE HOUSING AUTHORITY VS. SINCERRAE ROSS (LT-007964-19, HUDSON COUNTY AND STATEWIDE), A-1737-19

Bayonne Housing Authority (BHA) accused tenant Sincerrae Ross of lease violations, including permitting an unauthorized person (the father of her children) to receive mail at her public-housing unit.
BHA issued a termination notice and scheduled an administrative hearing; Ross did not appear and the administrative hearing was dismissed; BHA then filed a possession action in court.
At trial BHA introduced a BHA-generated address information/postal verification form (sent to and returned by the post office); defense counsel made no contemporaneous objection and the form was admitted.
Trial court found Ross violated the lease by receiving the father's mail (but did not find he lived there) and entered a judgment of possession based on the postal form.
Ross later sought to vacate the possession judgment and, for the first time, objected that the postal form was inadmissible hearsay; the trial court denied vacatur, concluding the form fell within the public‑records exception (N.J.R.E. 803(c)(8)).
On appeal the Appellate Division noted preservation defects but reviewed the evidentiary rulings for abuse of discretion and affirmed the denial of relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of BHA postal/address verification form under public‑records exception	The form is a BHA record sent to the post office for address verification and returned; qualifies under public‑records exception and is trustworthy	The postal form is hearsay and inadmissible; trial court relied solely on that form so possession judgment should be vacated	Admitted; trial court did not abuse discretion — form falls within public‑records exception and is trustworthy
Preservation / waiver of hearsay objection	Objection was not raised at trial; defense forfeited contemporaneous objection allowing admission	Objected later at show‑cause to vacate judgment — argues late objection should still permit relief	Appellate court stressed preservation rules and found the objection was raised too late; nevertheless addressed merits and found no abuse of discretion

Villanueva v. Zimmer, 431 N.J. Super. 301 (App. Div. 2013) (explains public‑records exception requirements)
State v. Robinson, 200 N.J. 1 (N.J. 2009) (issue preservation limits appellate review)
Nieder v. Royal Indem. Ins. Co., 62 N.J. 229 (N.J. 1977) (appellate courts generally do not consider unpreserved issues)
Pitney Bowes Bank, Inc. v. ABC Caging Fulfillment, 440 N.J. Super. 378 (App. Div. 2015) (standard for denying reconsideration)
Gac v. Gac, 186 N.J. 535 (N.J. 2006) (abuse of discretion standard for reviewing discretionary rulings)
State v. Matulewicz, 101 N.J. 27 (N.J. 1985) (records kept in regular course possess circumstantial trustworthiness)