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175 N.J. 402

815 A.2d 460

Carter v. Reynolds

Supreme Court of New Jersey

Decided February 19, 2003

Supreme Court of New Jersey · decided 2003-02-19

Key passage — most relied on by later courts

“to advance her employer's business interests fell within the dual purpose, required-vehicle exception to the going and coming rule and placed her squarely . . . within . . . the scope of her employment at the time of the accident.”

quoted by 2 later decisions, including Milwaukee Transport Services., Inc. v. Family Dollar Stores of Wisconsin, Inc., Lessard v. Coronado

Relies on O'TOOLE v. Carr

Good law ✅— No negative treatment on recordhow we know

Decided 2003-02-19

How this case has been cited

Cited by 56 later decisions — most recently November 2025 · most notably Lessard v. Coronado (2007), Lessard v. Coronado Paint & Decorating Center, Inc. (2007)

2 federal appellate · 11 district · 36 state decisions

310200320102020decided

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 →

LaVECCHIA, J.,

¶1concurring.

¶2I am able to join in the judgment of the Court and its narrow holding that applies the “required-vehicle” exception to the “going- and-coming” rule and imposes liability on this employer under a respondeat superior theory. Importantly, the Court eschews any reliance on “the broad enterprise liability theory that is the standard for respondeat superior in California.” Ante at 418, *420815 A.2d at 469; see also O’Toole v. Carr, 175 N.J. 421, 815 A.2d 471 (2003). The Court wisely declines to adopt a standard that effectively abandons consideration of employer control in the context of employee automobile accidents.

¶3I have no hesitation in agreeing with the Court’s assessment here that the employer exercised control and derived benefit from requiring its employee to have her motor vehicle at work that day and sending her, in that vehicle, to an alternate site to perform duties. Her employer thus must bear vicarious liability for the accident that occurred on her way home from that assignment. This was not the employee’s typical end-of-workday commute home from her regular worksite; it was a return home from assigned off-site work duties. In that setting, the cessation of workday duties did not signal the end of the employer’s control and derived benefit from the condition of employment that required the use of her vehicle in promotion of the employer’s interest.

¶4That said, fairly read, the Court’s opinion does not stand for the proposition that every invocation of the required-vehicle exception shall subject an employer to liability for an automobile accident occurring during an employee’s commutation. It surely has not been, and is not as a result of this decision, the law of this Court that all types of employees who commute to work by personal vehicle, and who may be sent, via their own vehicle, on assignment from time to time, now commute every day to and from their regular workplace “under the control” of their employer. The Court has never considered such a broadly sweeping application of the required-vehicle exception to the going-and-coming rule. The societal cost and benefit of such an across-the-board application of the required-vehicle exception to all employees who may have to commute to work by their own motor vehicle and who may have to use their vehicle occasionally in work-related business would require careful scrutiny,' but not today and not on these facts. Because that question is left for another day, I am able to join in the Court’s disposition.

*421For affirmance — Chief Justice PORITZ and Justices COLEMAN, LONG, VERNIERO, LaVECCHIA, ZAZZALI and ALBIN — 7.

¶5Opposed — None.

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