Crespo v. Stapf

I would make today’s ruling prospective. By its 1992 amendment of N.J.S.A. 2A:14-22, the Legislature has clarified that tolling does not occur in the case of nonresident defendants unless long-arm service cannot be effectuated. L.1991, c. 387. The Court (seeming to think that that law is a break with the past) declines to make the statute retroactive. Instead, it reasons that our 1983 decision in Coons v. American Honda Motor Co., 94 N.J. 307, 463 A.2d 921 (1983) (Coons I), modified, 96 N.J. 419, 476 A.2d 763 (1984) (Coons II), cert. denied, 469 U.S. 1123, 105 S.Ct. 808, 83 L.Ed.2d 800…