John C. Crispin and Michelle Crispin, His Wife, Plaintiffs-Respondents v. Volkswagenwerk, A.G., a West German…

Summary

The Supreme Court of New Jersey affirmed the lower courts' judgments, holding that the entire controversy doctrine should not be applied retroactively to compel joinder of parties and that the dismissal of the Bergen County action for failure to serve a summons within ten days was proper without prejudice. The Court also referred the plaintiff's counsel to the Office of Attorney Ethics for possible discipline. Justice Clifford dissented, arguing the dismissal should have been with prejudice due to the statute of limitations, while Justice Handler concurred, emphasizing support for extending the entire controversy doctrine to parties.