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121 N.J. Super. 213

296 A.2d 537

Watson v. Jaffe

DERYL WATSON, PLAINTIFF-APPELLANT, v. NATHAN JAFFE, DEFENDANT-RESPONDENT.

New Jersey Superior Court Appellate Division

Submitted October 30, 1972.

Decided November 10, 1972.

New Jersey Superior Court Appellate Division · decided 1972-11-10

Key passage — most relied on by later courts

“homogeneous and consistent whole, giving effect to all their provisions.”

quoted by 1 later decision, including 312 N.J. Super. 387 - Cty. of Camden v. S. Jersey Port

Good law ✅— No negative treatment on recordhow we know

Decided 1972-11-10

How this case has been cited

Cited by 26 later decisions — most recently March 2009 · most notably State v. Green (1973), 216 N.J. Super. 46 - Superior Air Prod. Co. v. NL Industries, Inc. (1987)

26 state decisions

1301972198019902000decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

¶1Before Judges COLLESTER, LEONARD and HALPERN.

¶2*214Mr. Eric A. Summerville, Newark Legal Services Project and Harris David, Director of Newark-Essex Joint Law Reform Project, attorneys for appellant (Messrs. Richard E. Blumberg and Barry Benefield, of counsel).

¶3Mr. Nathan Jaffe, pro se.

¶4PER CURIAM.

¶5The narrow issue on this appeal is whether the Security Deposit Act, N.J.S.A. 46:8-19 et seq., deprives a tenant of its benefits if he has been evicted for nonpayment of rent. The trial court held it did, and made no findings with respect to the issues requiring determination.

¶6We find nothing in the statutes adopted by the Legislature (L. 1971, c. 233, effective June 21, 1971), of which N.J.S.A. 46:8-21.1 is a part, to justify the trial court's conclusion. These enactments were in pari materia, and, on well-settled principles of interpretation, are to be considered as a homogeneous and consistent whole, giving effect to all their provisions. So construed, we are satisfied they were adopted to protect tenants from overreaching landlords who require rent security deposits from tenants and then divert such deposits to their personal use. The fact that plaintiff was evicted for nonpayment of rent is no reason to deprive him of whatever benefits he may be entitled to under the law.

¶7Reversed and remanded for a new trial. We do not retain jurisdiction.

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