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 deadline in N.J.S.A. 52:4B‑18 is a substantive limitation that may be tolled for a victim’s crime‑induced incapacity, so the plaintiff’s claim was timely and the Appellate Division’s denial was reversed and remanded. The dissent argued that the statutory deadline is a strict substantive condition that cannot be tolied and would have affirmed the lower court.