John Erickson, Plaintiff-Appellant v. Marsh & McLennan Co., Inc., Defendant-Respondent

Summary

The Supreme Court of New Jersey held that the plaintiff failed to establish a prima facie claim of reverse sex discrimination under the Law Against Discrimination and affirmed the dismissal of his retaliation claim, but it reversed the lower court's ruling on the libel claim and remanded for a new trial applying a clear‑and‑convincing‑evidence standard for actual malice. The Court also clarified the proper test for reverse discrimination claims and affirmed the applicability of a qualified privilege to employer reference letters.