National Law Review
7/16/2026

The original headline is 10 words: "NJ Supreme Court Clarifies Jury Allocation Rules for Out-of-State Tortfeasors"
Original: NJ Supreme Court Clarifies Jury Allocation Rules for Out-of-State Tortfeasors
Short summary
The New Jersey Supreme Court held in Estate of Crystal Walcott Spill v. Markovitz that juries may not allocate fault to out-of-state tortfeasors not subject to personal jurisdiction under the Comparative Negligence Act. However, defendants retain the right to seek contribution from such tortfeasors under the Joint Tortfeasors Contribution Law. The ruling creates a clear divide: CNA limits trial allocation to parties before the court, while JTCL permits broader post-judgment contribution.
- •Jury cannot allocate fault to out-of-state tortfeasors lacking personal jurisdiction under CNA
- •Defendants retain contribution rights under JTCL against non-party tortfeasors
- •Litigators must consider jurisdictional limits when developing multi-state tort strategy
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