Workers' Compensation: Employer Contribution Barred

On January 15, 2025, US District Judge Edward S. Kiel issued a significant decision in Wright v. Cezaire (Case No. 21-cv-13491), affirming the exclusivity provision of the New Jersey Workers' Compensation Act. This ruling has crucial implications for employers facing potential liability in third-party lawsuits.

Key Issue: Employer Immunity and Contribution

The central issue in Wright v. Cezaire revolved around the concept of "joint tortfeasor contribution." This legal doctrine allows a defendant found liable in a lawsuit to seek reimbursement from other parties who also contributed to the harm suffered by the plaintiff.

However, the New Jersey Workers' Compensation Act contains an "exclusivity provision." This provision generally bars employees from suing their employers for workplace injuries, instead directing them to the workers' compensation system. The question before Judge Kiel was whether this exclusivity provision also shielded employers from being named as joint tortfeasors and thus liable for contribution to other defendants in a third-party lawsuit.

Judge Kiel's Ruling: Exclusivity Prevails

Judge Kiel sided with the employer, finding that the New Jersey Workers' Compensation Act's exclusivity provision indeed barred the employer from being considered a joint tortfeasor for contribution purposes. The court reasoned that allowing contribution would undermine the core purpose of the exclusivity provision, which is to provide a swift and certain remedy for injured workers while limiting the potential liability of employers.

"...because the Worker's [sp Workers'] Compensation Act replaces a party's right to any other method, form or amount of compensation,' an "employer [also] cannot be subject to third-party claims pursuant to the Comparative Negligence Act." [internal quotation marks omited]

Implications for Employers

This decision provides a significant degree of protection for employers in New Jersey. It reinforces the principle that the workers' compensation system is the exclusive remedy for workplace injuries, shielding employers from potential financial exposure in third-party lawsuits.

Wright v Cezaire, 2025 WL 99596, Docket No. 21-cv-13491-ESK-AMD, (USDC NJ 2025) Filed 01/15/2025

Recommended Citation: Gelman, Jon., Employer Contribution Barred, www.gelmans.com (01/23/2025) https://workers-compensation.blogspot.com/2025/01/employer-contribution-barred.html

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*Jon L. Gelman of Wayne, NJ, is the author of NJ Workers’ Compensation Law (West-Thomson-Reuters) and co-author of the national treatise Modern Workers’ Compensation Law (West-Thomson-Reuters). For over five decades, the Law Offices of Jon Gelman 1.973.696.7900
jon@gelmans.com has represented injured workers and their families who have suffered occupational illnesses and diseases.