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VOL. 2 NO. 159 DECISIONS RELEASED SEPT. 14, 1994 TORTS 36-2-3984 Elizabeth Monaghan v. Holy Trinity Church, Archdiocese of Newark et al., App. Div. (13 pp.) Negligence complaint against parish and archdiocese was properly dismissed under Charitable Immunity Act, since plaintiff — a parishioner who slipped and fell in the parish parking lot after mass — was a beneficiary of the charitable organization’s works and the Act makes no exception for acts of alleged gross negligence. WORKERS’ COMPENSATION 39-2-3985 Katrese Watts v. Ponderosa Steak House, App. Div. (5 pp.) Award of 7+ percent of partial total disability due to “residuals of chronic lumbosacral strain and sprain” reversed and remanded where (1) petitioner — injured in June 1991 in a slip-and-fall accident — had not worked since the birth of her child in August 1992, and hearing was conducted two years after the accident without any re-examination prior to hearing and (2) judge of compensation failed to articulate objective medical evidence upon which he based finding of functional disability or to make findings that petitioner suffered a lessening of working ability to a material degree.

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