Supreme Court of New Jersey

Salve Chipola, III v. Sean Flannery

August 7, 2025

Summary

The Supreme Court of New Jersey held that false‑light invasion of privacy claims are governed by the one‑year statute of limitations applicable to defamation actions, affirming the Appellate Division’s dismissal of the plaintiff’s claim. The Court relied on the conduct‑based analysis articulated in McGrogan and the precedent set in Swan, emphasizing the similarity of the two torts and the policy of protecting free speech.