unconscionable commercial conduct

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