The Appellate Division vacated a trial court award of sanctions in a suit against a municipal tax assessor, stating that “merely discussing the fact that the court would address sanctions separately in another hearing is not the same as ordering severance under Rule 4:38-2(a).”

The vacated award, granted to Green Township, was issued as a result of frivolous litigation the township’s municipal tax assessor endured at the hands of a disgruntled resident who sought to increase the assessor’s property tax bill.

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