LINDSAY PALMISANO VS. STATE OF NEW JERSEY ADMINISTRATIVE OFFICE OF THE COURTS, ET AL. (L-2084-23, MERCER COUNTY AND STATEWIDE)

Summary

This appeal concerned whether a municipal court administrator qualifies as an employee of the New Jersey Administrative Office of the Courts (AOC) and can therefore bring a discrimination claim against the AOC under the Law Against Discrimination (LAD), N.J.S.A. 10:5-1 to -49.

After examining the relevant statutes and court rules, the Appellate Division noted that the Legislature could have expressly classified municipal court administrators as AOC employees but chose not to. Instead, N.J.S.A. 2B:12-10(a) directs municipalities — not the AOC — to provide and compensate court administrators, and N.J.S.A. 2B:12-1(a) requires each municipality to establish its own municipal court. While the AOC maintains supervisory authority and sets certain operational standards, this oversight does not create an employer-employee relationship with the plaintiff.

Held: The AOC was not the plaintiff’s employer for purposes of the LAD, and summary judgment in favor of the AOC was affirmed.