Sales Receipts Not Contracts Under TCCWNA, Appeals Court Says in Nixing Class Action
"We conclude that the complaint should have been dismissed with prejudice because the sales receipts are not a violation of the TCCWNA, and they are not contracts or notices under the act," said Appellate Division Judges Thomas Sumners Jr. and Scott Moynihan.
August 21, 2018 at 05:32 PM
3 minute read
A plaintiff in a putative class action cannot sue two northern New Jersey supermarkets for allegedly overcharging sales tax based solely on receipts he received from the stores, a New Jersey appeals court has ruled.
The Appellate Division in an unpublished opinion released Aug. 17 said the action lodged by plaintiff Frank Barile failed to state a claim under the Truth-in-Consumer Contract, Warranty and Notice Act.
“We conclude that the complaint should have been dismissed with prejudice because the sales receipts are not a violation of the TCCWNA, and they are not contracts or notices under the act,” said Appellate Division Judges Thomas Sumners Jr. and Scott Moynihan.
The appeals court also said that any dispute over alleged overcharges in sales taxes falls within the exclusive jurisdiction of the director of the state Division of Taxation.
Barile, according to the ruling, shopped at Gala Fresh stores in Paterson and Passaic several times over a three-week period in 2016. During that period, he was given sales receipts showing that he had been charged more in sales tax for taxable items than the 7 percent allowed by law at the time, he claimed.
He filed a putative class-action lawsuit alleging violations of the TCCWNA based solely on the sales receipts, the ruling said.
On a defense motion, Passaic County Superior Court Judge Randal Chiocca dismissed the lawsuit with prejudice. He said, under the TCCWNA, the sales receipts did not constitute contracts or guarantees, and that any offense was in the overcharging of sales taxes, which was an issue for the division to decide.
The panel, quoting from case law, noted that TCCWNA is a statute that prohibits certain affirmative actions—”'that is, the offering of or signing of a consumer contract, or giving or displaying of consumer warranties, notices, or signs, which violate a substantive provision of law.'”
Sales receipts memorialize the plaintiff's purchases, but go no further in substantiating a TCCWNA violation, the court said.
“The fact that the TCCWNA is remedial legislation does not allow us to impose requirements that are not within the four corners of its language,” the judges said.
Barile's attorney, Andrew Wolf, who heads a firm in North Brunswick, said: ”We are considering our options.”
The supermarkets' attorney, Douglas Sanchez of the Woodcliff Lake office of Cruser, Mitchell, Novits, Sanchez, Gaston & Zimet, did not return a call seeking comment.
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