Colt v. New Jersey Tr. Corp.

Summary

The court affirmed the Appellate Division's order, holding that New Jersey Transit Corporation is not an arm of New Jersey entitled to invoke interstate sovereign immunity in New York courts. The court adopted a three-factor inquiry focused on the entity's state-law definition and functions, the State's control over its conduct, and the effect of a judgment on the State, concluding that New Jersey's lack of legal or ultimate financial liability and NJT's autonomy outweighed the factors favoring immunity. The court also rejected the Appellate Division's use of forum non conveniens principles to override sovereign immunity.