Joyce Quinlan, Plaintiff-Appellant v. Curtiss-Wright Corporation, Defendant-Respondent

Summary

The Supreme Court of New Jersey reversed the Appellate Division, reinstating the jury’s verdict that the employer’s termination of Joyce Quinlan was unlawful retaliation under the Law Against Discrimination and that the punitive‑damage award was supported by evidence of especially egregious conduct. The Court affirmed the trial court’s distinction that copying confidential documents was unprotected, but the attorney’s use of a document in the deposition was protected activity, and it adopted a new multi‑factor balancing test for future cases. Justice ALBIN dissented, arguing the majority’s approach encourages theft of employer documents.