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HOELZ v. BOWERS

DOCKET No. A-1534-21.

278 A.3d 797 (2022)

473 N.J. Super. 42

Faye HOELZ, Plaintiff, v. Andrea Legath BOWERS, M.D., FAAOS, and/or Burlington County Orthopaedic Specialists, PA, Defendants/Third-Party Plaintiffs-Respondents, v. Lutheran Crossings Enhanced Living, Third-Party Defendant, and Walter Cominsky, D.O., Third-Party Defendant-Appellant.

Superior Court of New Jersey, Appellate Division.

Decided June 20, 2022.

Attorney(s) appearing for the Case

Mark A. Petraske argued the cause for appellant (Dughi, Hewit & Domalewski, Cranford, attorneys; Mark A. Petraske , Princeton, of counsel and on the briefs; Ryan A. Notarangelo , on the briefs).

Michael A. Pattanite, Jr. , argued the cause for respondents (Lenox, Socey, Formidoni, Giordano, Lang, Carrigg & Casey, LLC, Lawrenceville, attorneys; Michael A. Pattanite, Jr. , Lawrenceville, on the brief).

Before Judges Messano, Rose, and Enright.

The opinion of the court was delivered by

Prior to the 1952 enactment of the Joint Tortfeasors Contribution Law (the JTCL), N.J.S.A. 2A:53A-1 to -5, the common law of New Jersey "permitted a plaintiff to place the entire burden of fault on one defendant, who was then helpless to shift any of the responsibility to any other...

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