Supreme Court of New Jersey

Louis Panzino, Petitioner-Appellant v. Continental Can Company, Respondent-Respondent

September 29, 197671 N.J. 298

Summary

The Court held that the 1974 amendment to N.J.S.A. 34:15-34 applies retroactively, so Panzino's claim filed within two years of discovery is valid, and reversed the Appellate Division. The Court reasoned that legislative intent, liberal construction of the Workmen's Compensation Act, and the jurisdictional nature of the time limits support retroactive application, and found no due‑process violation. Justice Schreiber dissented, arguing that the amendment should not impair the employer’s vested right under the prior limitation period.