Supreme Court of New Jersey

Rebecca J. Reed v. Elizabeth M. Muoio

July 2, 2026

Summary

The Court held that the Council on Local Mandates is subject to judicial review when the question is whether it acted within the constitutional and statutory scope of its authority. Although the Council properly determined that the mobile-video-recording mandate was an unfunded mandate, it exceeded its authority by declaring a separate $25 DWI surcharge invalid. The Court therefore affirmed dismissal of the plaintiffs’ claims seeking refunds.