Estate of Crystal Walcott Spill v. Jacob E. Markovitz, M.D.

Summary

The Supreme Court of New Jersey held that an out‑of‑state doctor who is not subject to personal jurisdiction cannot be treated as a "party" for jury allocation of fault under the Comparative Negligence Act, but may be a joint tortfeasor for contribution claims under the Joint Tortfeasors Contribution Law. The judgment of the Appellate Division was affirmed as modified and the case was remanded.