In two published opinions, the Appellate Division reached opposing conclusions in deciding whether personal jurisdiction existed for dioceses named as defendants in claims of sexual abuse at the hands of Catholic priests.

In D.T. v. Archdiocese of Philadelphia, the plaintiff alleged that he was sexually abused by a former Catholic priest, Michael McCarthy, in New Jersey in 1971 when he was 14 years old. At that time, McCarthy was a priest and teacher in the Archdiocese of Philadelphia, which is named as a defendant in the case. D.T.’s claims against the archdiocese were dismissed for lack of personal jurisdiction because no facts established it purposely availed itself of any benefits in or from New Jersey related to the alleged abuse, according to the opinion. The appeals court affirmed that decision.