Since first issuing declarations of emergency in early March, the Governors of New York, New Jersey and Connecticut have been coordinating their COVID-19 response measures fairly closely, in recognition of the physical proximity and economic dependency of their States.

Each State is among each other’s top trade partners, and hundreds of thousands of people cross

In two recent decisions, New Jersey’s Appellate Division re-affirmed individuals acting within the scope of their employment can be personally liable under the State’s Consumer Fraud Act (the “CFA”), as well as related regulations governing home improvements, provided they actively participated in the consumer fraud. Lanza v. Secret Gardens, No. A-2613-07T22613-07T2 (App. Div. October 14