Employment decisions made in New Jersey are insufficient to give rise to a NJLAD claim for an out-of-state employee.

The plaintiff was a resident of the state of Washington, and she worked out of her home office as a sales manager for a New Jersey corporation. The plaintiff filed suit, alleging claims of sexual harassment and wrongful termination under federal, Washington and New Jersey statutes. In dismissing the claims brought under the NJLAD, Judge Martini held that the statute only applied to employment that took place in New Jersey as well as the fact that the corporation was located in New Jersey or that the employment decisions were made by persons living/working in New Jersey was insufficient.

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