Keith Williams v. Raymours Furniture Co., Inc.
159 A.3d 903
N.J. Super. Ct. App. Div.2017Background
- Petitioner Keith Williams, a New Jersey resident, applied online and was offered a warehouse job at Raymours' Suffern, New York facility by telephone; he accepted the offer while in New Jersey.
- Williams worked exclusively in the Suffern, NY warehouse and in 2014 suffered a work-related elbow fracture in New York.
- The New York Workers' Compensation Board ordered Raymours to provide medical and indemnity benefits.
- Over a year later Williams filed a workers' compensation claim petition in New Jersey. Raymours asserted lack of jurisdiction as an affirmative defense.
- The New Jersey judge of compensation dismissed Williams' New Jersey claim with prejudice, finding the injury and employment occurred in New York and New Jersey lacked jurisdiction.
- On appeal the Appellate Division reviewed de novo and reversed, holding New Jersey has jurisdiction because Williams formed the employment contract in New Jersey (acceptance by phone) and is a New Jersey resident.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether NJ has jurisdiction over a work injury occurring in NY when the employee is a NJ resident | Williams: Contract was formed in NJ (acceptance by phone) and his NJ residency supports NJ jurisdiction | Raymours: Accident and employment locale in NY mean NJ should not assert jurisdiction | NJ has jurisdiction because the contract was formed in NJ and petitioner resides in NJ; those contacts suffice |
| Whether a pending NY workers' compensation petition precludes NJ jurisdiction | Williams: NY proceeding does not bar NJ claim | Raymours: NY action should preclude NJ proceedings / implicate comity | Pending NY proceeding does not bar a NJ claim; comity is not an obstacle here |
| Whether offer and acceptance both must occur in NJ to fix situs of contract | Williams: Acceptance in NJ is sufficient to make NJ the place of contracting | Raymours: At least one party’s acts in NY make NJ inappropriate | Acceptance in NJ is the decisive act; contract is formed where final act of formation occurs (NJ) |
Key Cases Cited
- Williams v. Port Auth. of N.Y. & N.J., 175 N.J. 82 (N.J. 2003) (New Jersey will assert jurisdiction when the State has a substantial interest)
- Connolly v. Port Auth. of N.Y. & N.J., 317 N.J. Super. 315 (App. Div. 1998) (workers' compensation jurisdiction is statutory and limited; multiple states with interest may apply their acts)
- Gotkin v. Weinberg, 2 N.J. 305 (N.J. 1949) (place of hiring/contract formation can confer jurisdiction)
- Filson v. Bell Tel. Labs., Inc., 82 N.J. Super. 185 (App. Div. 1964) (contract is made where the final act necessary for formation is done)
- Gomez v. Federal Stevedoring Co., Inc., 5 N.J. Super. 100 (App. Div. 1949) (acceptance in-state fixes situs of contract even if offer originated elsewhere)
- Bunk v. Port Auth. of N.Y. & N.J., 144 N.J. 176 (N.J. 1996) (resident's ability to bring action in NJ noted; residence supports jurisdiction)