Serrano v. Gibson

The opinion of the court was delivered by

CONLEY, J.A.D.

In Chatman v. Hall, 128 N.J. 394, 419-20, 608 A.2d 263 (1992), the Supreme Court reaffirmed that the ninety-day notice requirement of the Tort Claims Act was not applicable to claims against public employees. See Williams v. Adams, 189 N.J.Super. 196, 198-99, 459 A.2d 707 (Law Div.1983); Lutz v. Semcer, 126 N.J.Super. 288, 300, 314 A.2d 86 (Law Div.1974). Effective June 23, 1994, N.J.S.A. 59:8-3 and N.J.S.A. 59:8-8 were amended to subject such claims to that notice requirement. L. 1994, c. 49, §§ 2, 4 (1994 amendments).1 As stated in the…