In two companion cases, Perez v. Zagami, LLC, A-36-12 (May 21, 2014), and Cottrell v. Zagami, A-5-13 (May 21, 2014), the New Jersey Supreme Court confirmed that the New Jersey Civil Rights Act (NJCRA) offers no private cause of action against individuals except for those who are acting under color of law. The Court ruled that while the Attorney General retains the authority to bring non-“color of law” claims, a private claim under the NJCRA requires the presence of state action. While private employment claims under the NJCRA are rare to date, following Zagami, they should become nonexistent.


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