JAMES G. KEELAN, PLAINTIFF-APPELLANT, v. BELL COMMUNICATIONS RESEARCH, DEFENDANT-RESPONDENT., 289 N.J. Super. 531

Summary

Plaintiff employee claimed he was terminated by defendant employer because he opposed defendant's failure to protect the safety of its employees. Plaintiff signed a release form and received a termination allowance. The court held that the one-year limitations period of the New Jersey Conscientious Employee Protection Act (CEPA), N.J. Stat. Ann. § 34:19-1 et seq., commenced on the date of plaintiff's actual termination rather than on the date he received notice, making his claim timely filed. The court reversed the grant of summary judgment to defendant because genuine material issues existed a to the voluntariness of the release signed by plaintiff. The court held that, while it was not required that the release specifically refer to CEPA in order to bar claims under that statute, the failure to mention CEPA raised a material issue of whether the release was knowing and voluntary. Additionally, the court noted that plaintiff had only seven days to review the second page of the release...