Czar, Inc. v. Heath

In order to shoehorn construction work on a new home that had not been completed, permitted, or even ever occupied into the Consumer Fraud Act (CFA), N.J.S.A. 56:8-1 to -20, the majority concludes that “plaintiff, which neither acted as the general contractor nor qualified as a builder of new homes, was engaged in the business of home improvements and subject to the remedies of the CFA.” Ante at 197, 966 A.2d at 1009. According to the majority, the CFA and the New Home Warranty and Builders’ Registration Act (the New Homeowners Warranty or HOW Act), N.J.S.A. 46:3B-1 to -20, are “designed to…