Philadelphia-Based Employee’s CEPA and NJLAD Claims Dismissed Even Though Employee Managed New Jersey Accounts, New Jersey District Court Rules

In Papalini v. Sensient Colors, Inc., a Philadelphia-based account manager filed a complaint against her employer alleging sexual harassment under the NJLAD and retaliation under CEPA, which are both New Jersey statutes, as opposed to federal or Pennsylvania statutes. Civ. No. 11-6392 (D.N.J. Apr. 18, 2012). The court dismissed the plaintiff’s claims, holding that the plaintiff’s lone connection to New Jersey – the fact that as a regional account manager a significant portion of her accounts were in New Jersey – was insufficient to render her a New Jersey employee for purposes of protection under CEPA or the NJLAD.