On Feb. 28, 2024, the New Jersey Superior Court, Appellate Division, published a precedential opinion in six consolidated lawsuits filed by sexual abuse victims claiming to have been assaulted decades earlier when they were minors and participants in a New Jersey nonprofit youth organization. E.T. v. Boys & Girls Club, no. A-3720-22, 2024 N.J. Super. LEXIS 21 (N.J. App. Div. Feb. 28, 2024). Disagreeing with and reversing the ruling of the trial court, the Appellate Division held that its state courts do not have personal jurisdiction over an out-of-state national organization that is affiliated with a New Jersey nonprofit where plaintiffs claim to have been sexually abused by a counselor of the New Jersey entity within its borders.

Following a series of impactful decisions in December 2023, which established the personal jurisdiction requirements for out-of-state religious institutions sued in New Jersey based upon claimed abuse by clergymen in their parishes, the appellate panel found that “the national organization did not purposely avail itself of benefits in or from New Jersey regarding the alleged sexual abuser, and hence, our state has no specific personal jurisdiction over the national organization … ” See e.g., D.T. v. Archdiocese of Phila., 477 N.J. Super. 370, 307 A.3d 37 (N.J. App. Div. 2023); Doe v. Diocese, 477 N.J. Super 270, 306 A.3d 237 (N.J. App. Div. 2023).