## Facts

- In January 2001, two-year-old S.A. was brought to a hospital emergency room with vomiting and inability to walk.
- The treating physician, Dr. Daniel Yu, noted a smell consistent with cologne/chemical alcohol, and testing showed an elevated blood alcohol level.
- S.A.’s father arrived and produced a bottle of cologne, stating S.A. ingested it; Dr. Yu diagnosed accidental cologne ingestion.
- Dr. Yu discharged S.A. to her father and did not report suspected child abuse to the state child-protection agency under N.J.S.A. 9:6-8.10.
- In the following months, S.A. was later treated for a chemical burn; the agency received reports of burns and belt marks and substantiated abuse but initially did not remove S.A. from the home.
- After a later report describing extreme abuse and multiple injuries, the agency removed S.A. from the home; S.A. was later adopted by L.A.
- L.A., individually and on S.A.’s behalf, sued, alleging Dr. Yu and the hospital breached the mandatory reporting duty and that timely reporting would have prevented later abuse.

## Issues

1. Whether the information available to the physician during the January 2001 visit constituted “reasonable cause to believe” abuse or neglect occurred, triggering a mandatory report under N.J.S.A. 9:6-8.10.
2. Whether summary judgment was proper on claims seeking civil liability for failure to report suspected abuse where the record allegedly did not show the statutory reporting threshold was met.

## Decision

- The New Jersey Supreme Court reversed the Appellate Division and reinstated the Law Division’s summary judgment for Dr. Yu and the hospital.
- The Court treated “reasonable cause to believe” as an objective, suspicion-based standard, but held the summary-judgment record could not support a finding that the threshold was met at the January 2001 encounter.
- A medically plausible explanation of accidental ingestion, without contemporaneous signs indicating inflicted injury or neglect, did not obligate a report as a matter of law.
- Later-discovered abuse could not retroactively supply reasonable cause at the earlier visit.

## Legal Principles

- The mandatory child-abuse reporting statute imposes an objective “reasonable cause to believe” threshold that is lower than proof of abuse, but requires fact-based suspicion rather than conjecture.
- Whether a clinician has reasonable cause must be evaluated in context, including the clinical presentation, testing, examination findings, and the plausibility of accidental explanations based on information available at the time.
- Civil claims premised on failure to report require a showing that the reporting duty was triggered and breached; if the record cannot establish reasonable cause at the relevant encounter, summary judgment is appropriate.
- Subsequent events and later-confirmed abuse do not create or expand a prior statutory duty to report when the earlier circumstances did not support reasonable suspicion.

## Conclusion

The court held that, although New Jersey’s reporting statute favors prompt reporting when objective facts support suspicion of abuse, the physician’s January 2001 evaluation and the available explanation of accidental ingestion did not provide reasonable cause to believe abuse or neglect occurred; therefore, no reporting duty was triggered on that record and summary judgment for the physician and hospital was proper.


L.A. ex rel. S.A. & L.A. v. Div. of Youth & Fam. Servs., 217 N.J. 311 (2014)