With Bryan Churgin
In Carmona v. Resorts International Hotel, No. A-83-05 (February 21, 2007), the New Jersey Supreme Court held, in a case of first impression, that a plaintiff asserting a statutory retaliation claim under the New Jersey Law Against Discrimination ("LAD") must prove, as part of the prima facie case, that an initial complaint was filed reasonably and in good faith, and that an unreasonable, frivolous or bad-faith complaint is an insufficient basis to establish a LAD retaliation claim.