In a published opinion, the New Jersey Appellate Division held that there is no well-established common-law rule in the state that a physician has the duty to warn third persons against possible exposure to contagious or infectious diseases, such as COVID-19.

In Estate of Campbell v. Woodcliff Health and Rehabilitation Center, the plaintiffs claimed that Donville Campbell’s death was the result of “negligent, grossly negligent, careless and reckless actions and omissions” by discharging his wife, Selva Campbell, from a rehabilitation facility in April 2020 while the result of her COVID-19 polymerase chain reaction (PCR) test was pending, according to the opinion.