The Supreme Court of New Jersey entered its annual omnibus rule amendment order on July 23, 2026, with the amendments taking effect September 1, 2026. The order amends 22 rules governing general application, appellate, civil, and Tax Court practice, along with two appendices and RPCs 1.8 and 1.13. Of those, two changes touch on appellate practice.
New R. 4:48-1(b): Appeals After Accepting Payment of a Judgment
R. 4:48-1, which governs warrants of satisfaction, gains a new paragraph (b) under the amendments, codifying a standard previously adopted by the Court. In Brehme v. Irwin, 259 N.J. 505 (2025), a unanimous Court adopted a two-part test, held that the plaintiff satisfied neither prong, affirmed the dismissal of her appeal as moot, and referred the opinion to the Civil Practice Committee to consider clarifying R. 4:48-1. The Committee’s amendment tracks the Court’s ruling almost verbatim and specifically provides that a party may appeal after accepting payment of a final