NEW JERSEY MOTOR VEHICLE COMMISSION VS. GERARD J. REDMONDÂ (NEW JERSEY MOTOR VEHICLE COMMISSION), A-4157-15T4

On May 8, 2011, Redmond’s car rolled into an intersection after he was startled by an insect, striking another vehicle whose driver (decedent) had the green light.
Jackson police interviewed both drivers at the scene; Redmond was cited for failure to observe a traffic control device and pled guilty in municipal court.
The decedent was hospitalized after the crash and died six weeks later; the contemporaneous death certificate listed respiratory failure due to bilateral pneumonia.
In 2014 the decedent’s estate obtained medical opinions and an amended death certificate attributing death to the motor vehicle accident; the estate also sued Redmond civilly.
The MVC suspended Redmond’s license under N.J.S.A. 39:5-30 for a period (initially 16 months, reduced by the ALJ to 6 months), concluding Redmond’s failure contributed to a fatality; Redmond appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the motor vehicle accident caused the decedent’s death	Estate/Commission: amended death certificate and expert opinions show the accident caused death	Redmond: amended certificate years later is unreliable and may have been altered for civil advantage; alternate hospital-acquired conditions could explain death	Court accepted ALJ’s finding that the amended death certificate and expert opinions supported causation by a preponderance of evidence
Whether suspension (and its length) was appropriate	Commission/ALJ: suspension (reduced to 6 months) is a proper prophylactic remedy given negligence causing a fatality	Redmond: six‑month suspension was arbitrary/unreasonable, especially where negligence was not willful and the death attribution was contested	Court found suspension within statutory authority but remanded because relying on Redmond’s refusal to accept the amended death certificate as an aggravating factor was an abuse of discretion; remanded to reconsider suspension length under proper factors

Brady v. Bd. of Review, 152 N.J. 197 (review of administrative decisions is deferential)
N.J. Soc’y for Prevention of Cruelty to Animals v. N.J. Dep’t of Agric., 196 N.J. 366 (agency decisions upheld unless arbitrary, capricious, or unsupported by substantial evidence)
Henry v. Rahway State Prison, 81 N.J. 571 (standard for overturning administrative findings)
In re Tukes, 449 N.J. Super. 143 (appellate review of administrative findings)
Cresse v. Parsekian, 81 N.J. Super. 536 (director must weigh factors when determining suspension and its length)
Atkinson v. Parsekian, 37 N.J. 143 (agency proceedings require proof by preponderance of believable evidence)
In re Herrmann, 192 N.J. 19 (deference to agency remedy choice where public policy implicated)
Div. of State Police v. Jiras, 305 N.J. Super. 476 (sanction review and agency discretion)