Elizabeth White, Plaintiff-Appellant v. Violent Crimes Compensation Board, an Agency of the State of New Jersey…

Summary

The Supreme Court of New Jersey held that the one‑year filing limitation in N.J.S.A. 52:4B-18 may be tolled for the period a victim is incapacitated by the crime, so Elizabeth White's claim was timely and the Appellate Division's denial was reversed and remanded. The Court based its decision on a purposive interpretation of the statute, treating the limitation as a substantive provision that can be flexibly applied when legislative intent is served. Justice Conford dissented, arguing that the statute imposes a strict, unconditional deadline that cannot be judicially extended.