L.A. v. New Jersey Division of Youth & Family Services, 217 N.J. 311

Background

Two-year-old S.A. presented to Jersey Shore Univ. Med. Ctr. ER with lethargy, vomiting and a cologne/ethanol odor on her breath; blood alcohol 0.035%. Dr. Daniel Yu treated and discharged her the same night after IV fluids and testing.
Dr. Yu diagnosed accidental cologne ingestion, did not ask how ingestion occurred, did not document bottle details, and did not report to DYFS.
In the months after the ER visit, DYFS received separate reports revealing extensive abuse; S.A. was removed and later adopted by L.A., who sued Dr. Yu and the hospital for malpractice based on an alleged failure to report under N.J.S.A. 9:6-8.10.
Trial court granted summary judgment for defendants, finding no reasonable cause to believe abuse had occurred; Appellate Division reversed, applying a “probable inference” standard drawn from N.J.S.A. 9:6-8.16 and remanding for trial.
Supreme Court granted review to resolve the proper interpretation of the statutory reporting trigger “reasonable cause to believe” and whether Dr. Yu breached that duty given the ER facts.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper interpretation of “reasonable cause to believe” in N.J.S.A. 9:6-8.10	Appellate Division/L.A.: standard informed by N.J.S.A. 9:6-8.16; reporting required when a “probable inference” of reckless/grossly negligent conduct exists	Dr. Yu: statute uses familiar “reasonable cause” language requiring an objective, ordinary-prudent-person test; should not be expanded by § 9:6-8.16	Court: “reasonable cause to believe” is an objective reasonableness test applied to the facts known to the person on the scene; do not import § 9:6-8.16’s “most probable inference” standard
Whether physicians have a different or heightened reporting standard	L.A.: physicians’ duties can be informed by physician-specific statutes and higher suspicion may be appropriate	Dr. Yu: Legislature intended one uniform standard for all persons; physician-specific statutes (e.g., § 9:6-8.16) authorize different remedies but do not alter the reporting trigger	Court: The general § 9:6-8.10 applies to all persons, including physicians; § 9:6-8.16 is distinct and does not change the reporting threshold
Whether accidental ingestion of a common household item (cologne) required reporting	L.A.: accidental ingestion can indicate abuse; facts available could support inference of recklessness or gross negligence	Dr. Yu: ingestion of common household items is not inherently grossly negligent; reporting every such ER presentation would create over-reporting and chill care	Court: Objectively, facts known to Dr. Yu did not support a reasonable belief of gross negligence/recklessness; no reporting breach
Effect of subsequent abuse revelations on reasonableness of initial non-report	L.A.: later abuse suggests earlier signs might have been reportable	Dr. Yu: later events cannot retroactively make the initial clinical judgment unreasonable	Court: Later discoveries do not change the objective reasonableness of the physician’s contemporaneous decision; cannot fault Dr. Yu based on later events

Key Cases Cited

G.S. v. Dep’t of Human Servs., 157 N.J. 161 (1999) (accidental ingestion can indicate abuse; “minimum degree of care” denotes grossly or wantonly negligent conduct)
T.B. (Dep’t of Children & Families v. T.B.), 207 N.J. 294 (2011) (distinguishes grossly negligent/reckless conduct from mere negligence in abuse/neglect context)
Frugis v. Bracigliano, 177 N.J. 250 (2003) (school personnel had independent reporting duties under § 9:6-8.10)
F.A. by P.A. v. W.J.F., 280 N.J. Super. 570 (App. Div. 1995) (objective test for reasonableness in reporting/immunity cases)
Graham v. Connor, 490 U.S. 386 (1989) (reasonableness standards assessed objectively from on‑scene perspective)
Brill v. Guardian Life Ins. Co., 142 N.J. 520 (1995) (standard for summary judgment review)
Coyne v. N.J. Dep’t of Transp., 182 N.J. 481 (2005) (de novo appellate review of summary judgment)