The New Jersey Appellate Division rejected a plaintiff's contention that the "ongoing storm rule," established by the New Jersey Supreme Court in Pareja v. Princeton International Properties, does not apply to privately owned commercial property.

In Smith v. Costco Wholesale, an Essex County Superior Court judge granted summary judgment to the retail giant in which Carol Smith alleged she was injured in a March 2018 slip and fall in front of the store. Judge Keith E. Lynott granted the motion and dismissed Smith's action, finding that the New Jersey Supreme Court holding in Pareja applies.