Joseph A. Donelson, Plaintiff, and John Seddon, Plaintiff-Appellant v. Dupont Chambers Works, Defendant-Respondent…

Summary

The Supreme Court of New Jersey reversed the Appellate Division and reinstated the jury's verdict awarding economic and punitive damages to plaintiff John Seddon under the Conscientious Employee Protection Act (CEPA). The Court held that CEPA does not require proof of constructive discharge for a lost‑wage claim when retaliation causes a psychological disability that renders the employee unable to work. The decision was based on a plain‑language reading of CEPA and the statute’s remedial purpose. Justice LaVECCHIA dissented, arguing that the majority improperly expands CEPA remedies beyond the statutory scheme.