D.T. v. Archdiocese of Philadelphia, ___ N.J. ___ (2025).  This unanimous opinion by Justice Patterson involved whether New Jersey courts had personal juriisdiction over the Archdiocese of Philadelphia, a defendant.  Suing both the Diocese and Michael J. McCarthy, a priest assigned by the Archdiocese to a Pennsylvania parish, plaintiff alleged that McCarthy had sexually abused him during an overnight trip to a private home in New Jersey.  On leave to appeal, as discussed here, the Appellate Division affirmed a ruling of the Law Division that New Jersey courts lacked personal jurisdiction over the Archdiocese on the facts presented.  The Supreme Court granted leave to appeal and affirmed in a unanimous opinion by Justice Patterson, who stated that "an n appellate court reviews de novo a trial court’s legal determinations regarding personal jurisdiction, but its review of a trial ‘court’s factual findings with respect to jurisdiction’ is limited to determining whether those findings are supported by substantial, credible evidence in the record."

"D.T. relie[d] on the Archdiocese’s authority over McCarthy’s work as a priest, particularly its direction to McCarthy to live in a Pennsylvania parish, mentoring and counseling parish families. He contend[ed] that because McCarthy’s status as a priest facilitated his alleged sexual assault of D.T. in New Jersey, McCarthy was the Archdiocese’s agent when he traveled to New Jersey, and the Archdiocese is subject to specific jurisdiction in New Jersey courts."  That argument rested on two cases that Justice Patterson found inapposite because hey involved agency principles, not personal jurisdiction.  She emphasized that agency principles do not displace the traditional due process analysis that looks to sufficient contacts between the defendant and the forum state.  "When [the Archdiocese] assigned McCarthy to D.T.’s parish and directed him to minister to its parishioners, the Archdiocese did not transcend the borders of its home state," Pennsylvania. 

Plaintiff's own allegations, if assumed to be true, made clear that McCarthy, not the Archdiocese, "  initiated and maintained contacts with New Jersey that are relevant to this case.  It was McCarthy, not the Archdiocese, who either owned or had access to the private home in Margate where the sexual abuse allegedly occurred.  It was McCarthy, not the Archdiocese, who sought and obtained the permission of D.T.’s mother to take him on an overnight trip.  And it was McCarthy, not the Archdiocese, who allegedly drove D.T. to Margate where he sexually assaulted the boy. There is no evidence that any Archdiocese representative was aware of McCarthy’s impending trip, let alone that it assigned McCarthy to take D.T. to New Jersey.  There is no evidence that McCarthy conducted business on behalf of the Archdiocese in New Jersey, or that the trip entailed any religious or ecclesiastical activities."  The Court concluded that the Law Division's findings were "grounded in substantial credible evidence in the record" and affirmed the Appellate Division's ruling upholding the Law Division's decision that personal jurisdiction was lacking.  

The Court found distinguishable "Doe 70 v. Diocese of Metuchen, 477 N.J. Super. 270, 284-87 (App. Div. 2023), decided on the same day as the Appellate Division’s decision in this appeal."  As discussed in the link above, the facts there were very different and thus supported personal jurisdiction.