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

Summary

The New Jersey Supreme Court reversed the Appellate Division, reinstating the jury's verdict on Joyce Quinlan's retaliation claim and the punitive damages award, holding that the trial court's distinction between copying confidential documents (unprotected) and the attorneys' use of those documents (protected) was correct. The Court also adopted a new multi‑factor balancing test for determining when an employee’s taking or use of employer documents is protected activity under the LAD.