Luz M. Cruz, Petitioner-Respondent v. Central Jersey Landscaping, Inc., Respondent-Appellant; Valentyna Hohl…

Summary

The Supreme Court of New Jersey held that the 2004 amendment to the Workers' Compensation Act's death benefit schedule applies only prospectively and not retroactively to claims pending or settled before its effective date. Accordingly, the Court reversed the Appellate Division's retroactive application, reinstated the pre‑amendment benefit awards for Cruz and Hohl, remanded Bush's case for further proceedings, and vacated Herzer's order. The decision rests on a plain‑language analysis of the amendment, the absence of legislative intent for retroactivity, and established rules favoring prospective application of statutes.