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News Briefs and Decision Summaries from NJSBA, August 15, 2025

These News Briefs and Decision Summaries are from  the  the New Jersey State Bar Association. They are an exclusive benefit of the Association in partnership with the New Jersey Law Journal. A subscription may be necessary to access the full text of some of the items listed:

Legal News

This week’s Capitol Report covers the state Supreme Court’s 2025 Omnibus Rule Amendments that will implement changes to civil, family and criminal practices. The NJSBA supported many of the amendments. Read the full report 

A federal judge has rejected several New Jersey parents’ claims that the state’s practice of retaining blood samples from its mandatory newborn disease screening program violates their constitutional rights. U.S. District Court Judge Georgette Castner dismissed a lawsuit, first filed in 2023, that sought to stop the state from storing leftover “blood spots,” which hospitals take by pricking the heels of newborns, for uses beyond disease detection. 

Keep your finger on the pulse of the latest developments in media law through this NJSBA Special Committee. To join, fill out the form  and discover the NJSBA’s wide range of Special Committees for every practice area.

In 2015, shortly after the Supreme Court recognized a constitutional right to same-sex marriage in Obergefell v. Hodges, a local county clerk from Kentucky made national headlines when she refused on religious grounds to issue a marriage license to a gay couple. That clerk, Kim Davis, is back in the news again this summer, this time because she has asked the justices to overturn their 2015 decision. 

Check out the New Jersey Institute for Continuing Legal Education’s on-demand library to stream award-winning CLE programs, available 24/7 worldwide. 

Supreme Court and Appellate Decision Summaries

Click on any decision below to get the full opinion from the New Jersey Judiciary – August 14, 2025

APPROVED FOR PUBLICATION

Criminal/Federal Inmate Rights

 – In limited contexts, the U.S. Supreme Court recognizes a cause of action against federal officers to redress a violation of constitutional rights. Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388, 397 (1971). Ronaldo Muniz, a federal inmate, challenged the District Court’s denial of a Bivens remedy for his Eighth Amendment deliberate indifference claim, arguing that his case is sufficiently analogous to the Supreme Court’s decision in Carlson v. Green, 446 U.S. 14 (1980), that his claim should proceed. Because this Court’s opinion in Kalu v. Spaulding, 113 F.4th 311 (3d Cir. 2024), held the availability of an alternative remedy creates a new context from Carlson and cautions against implying a new Bivens cause of action, the Third Circuit disagreed. Muniz’s Bivens claim cannot proceed because he had access to the Bureau of Prisons (“BOP”) administrative remedial mechanism (“ARP”). Muniz also challenged the dismissal of his claim under the Rehabilitation Act, 29 U.S.C. § 794. But he conceded on appeal that his claim is barred by federal sovereign immunity. The Third Circuit affirmed.

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