Category: Discrimination

Riot Games Settles in Gender Discrimination Lawsuit

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League of Legends developer, Riot Games, will have to pay over $10 million to settle a class action lawsuit that was filed on behalf of approximately 1,000 women who worked for the company over the past five years. According to court documents, the plaintiffs alleged that the company established a clear pattern of discrimination and sexual harassment. In addition, female employees claimed that they did not receive equal compensation compared to their male counterparts. This was a violation of the California Equal Pay Act—many states such as Pennsylvania and New Jersey have a similar law.

According to the terms of the settlement, each of the roughly 1,000 women who worked at Riot Games over the past five years is eligible to receive a portion of the settlement. The exact amount that each woman will receive depends on seniority, how long they worked at the company, and employment status, but most members of the class-action lawsuit will receive a minimum of $5,000. Full-time employees will receive more settlement money than part-time workers or contractors.

Investigation Reveals Sexist Culture

An investigation into the culture at Riot Games revealed a sexist environment where women were frequently exposed to “crotch grabbing,” “phantom humping,” and hot girl lists. Two women who initially sued Riot Games alleged that there were several women who did not receive equal pay, and who felt that their careers were being stifled by male employees. Several female employees alleged that they received pictures of the male genitalia. The lawsuit also accused the company of denying promotions to deserving female employees because they spoke out against the company’s male culture. In some cases, they were demoted or their benefits were withheld.

After Riot Games filed a motion to force plaintiffs into arbitration, over 150 employees walked out of the office to protest the motion. According to a Riot Games spokesperson, the company looks forward to resolving the lawsuit, and plans to demonstrate their commitment to creating an inclusive and supportive environment for all employees. However, several employees commented that the company’s efforts were overshadowed by the harmful workplace behavior and an ongoing pattern of filling senior positions with male employees.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green P.C. Represent Victims of Gender Discrimination

If you were discriminated against by your employer or another co-worker because of your gender, you are urged to contact the Philadelphia employment lawyers at Sidkoff, Pincus & Green P.C. at your earliest convenience. Employment discrimination laws prohibit employers from harassing employers based on gender, and from retaliating against an employee for reporting discriminatory behavior. Our experienced legal team will ensure that your rights are protected and that you receive the maximum financial compensation you deserve. To schedule a confidential consultation with one of our highly skilled employment lawyers, call us today at 215-574-0600 or contact us online. Located in Philadelphia, we serve clients throughout Pennsylvania and New Jersey.

Understanding Employment Law Helps Businesses Avoid Future Lawsuits  

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When employers appreciate and respect their employees by offering competitive salaries and benefits packages, opportunities for promotions, and paid time off, their employees are generally more productive and loyal to the company. However, if an employee has been discriminated against or accuses the company of legal wrongdoing, an employer could face serious legal issues if they do not know how to protect themselves from lawsuits and discrimination claims. An experienced employment lawyer can answer all your questions and prepare the legal documents necessary to protect your company from future lawsuits.

One of the most important steps companies should take to avoid serious employment law disputes is to draft a comprehensive, detailed contract that takes as many possibilities into consideration as possible. This is true regardless of how big or small your company is. There is a tendency for entrepreneurs and small business owners to assume that employment law only applies to larger corporations. They do not always consider the fact that small business owners can get into hot water if they make bad hiring and firing decisions or treat their employees poorly.

Importance of Paid Time Off

Employers do not always recognize the value of giving employees paid leave. While some may think it is an unproductive expense, it pays off in the long run by encouraging employees to prioritize their health and wellbeing. Ultimately, this builds job satisfaction and productivity. In addition, if an employer expects employees to work long hours during a particularly busy time, they may be less likely to complain, or accuse the company of unfair treatment if they can take advantage of paid days off.

Employers should also make it a habit of documenting everything that happens in the workplace. For example, if an employee is injured, fill out a detailed accident report that includes information about how the accident occurred and how the company will handle it. Depending on the company size, employers may want to consider hiring a dedicated specialist that can help manage a company’s records.

Hiring an employment lawyer is a significant expense, but one that can save thousands of dollars. An employment lawyer should protect the company and have a thorough understanding of contracts and policies. However, they should not attempt to confuse an employee who accused the company of wrongdoing, simply to try and outwit them. Companies cannot depend on their legal team to bend the rules on their behalf.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green P.C. Provide Skilled Legal Counsel for Employers

The Philadelphia employment lawyers at Sidkoff, Pincus & Green P.C. are highly skilled in all areas of law that impact the employer-employee relationship, including discrimination, harassment, and wrongful termination. Our experienced legal team will work closely with you to create a litigation strategy that addresses your specific concerns. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Located in Philadelphia, we serve clients throughout New Jersey and Pennsylvania.

Supreme Court to Determine Whether Title VII Protections Include Sexual Orientation or Gender Status

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In October 2019, the United States Supreme Court heard arguments in a set of cases that could have a major impact on federal discrimination law, particularly as it applies to LGBTQ employees. The three cases involved two gay men and one transgender woman who were allegedly terminated because of their sexual orientation or gender status. According to the Title VII of the Civil Rights Act of 1964, an employer may not discriminate against an employee based on sex, race, national origin, or religion. The court will consider whether employers should be legally allowed to fire an employee simply because they are gay or transgender.

Case Facts

In the first case, a child-welfare coordinator for Clayton County, Georgia advocated for abused and neglected children. He was very successful at this job and loved helping underprivileged children. Yet, after his employer discovered he was gay, he was fired. Not only did he lose his job, but he lost his income and health insurance, which was devastating since he was fighting prostate cancer.

In the second case, a transgender woman who worked as a funeral director at the Harris Funeral Home in Livonia, Michigan decided to come out to her boss and co-workers and tell them about her gender identity. Two weeks after she wrote a letter to her boss explaining her situation, she was fired.

In the last case, a sky-diving instructor at Altitude Express went on tandem skydiving excursions with clients. He often informed female clients that he was gay in case they were uncomfortable about being strapped to a man during the tandem jump. The employee was fired after a female client claimed that he touched her inappropriately. However, according to employee, this never happened, and he was fired because of his sexual orientation.

Many of the Court’s conservative judges were skeptical about the arguments made by the plaintiffs’ lawyers and were opposed to finding that Title VII included protections for LGBTQ workers. However, they will have to examine the literal text of the law and consider the fact that the plaintiffs would not have been fired if they were straight. The more liberal justices will have to consider that, when the Civil Rights Act of 1964 was passed, it was not likely that Congress intended it to prohibit against LGBTQ employees. In fact, homosexuality was considered a mental illness by the American Psychiatric Association in 1964.

If the Court rules in favor of the plaintiffs, discrimination cases involving LGBTQ workers will be treated the same as any other Title VII discrimination case. Employers will need to update their discrimination policies and train workers on how to comply with the new policies. If the Court rules against the plaintiffs, things will remain the same. Employers who already have anti-discrimination policies in place may continue to enforce them. The Court is expected to decide by June 2020.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green P.C. Protect the Rights of Employees

If you were discriminated at the workplace due to your protected status, contact the Philadelphia employment lawyers at Sidkoff, Pincus & Green P.C. We will protect your rights and secure the maximum financial compensation you deserve. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Located in Philadelphia, we serve clients throughout New Jersey and Pennsylvania.

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Federal Judge Grants U.S. Women’s Soccer Team Class Status in Gender Discrimination Lawsuit

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The U.S. Women’s National Team filed a lawsuit against the U.S. Soccer Federation (“USSF”) alleging that they do not receive equal pay compared to the men’s team. In addition, they argued that their work conditions are not as favorable as the men’s conditions. This has been an ongoing fight among female athletes for years. U.S. District Judge R. Gary Klausner ruled in favor of the women’s soccer team, saying that the class representatives had standing to pursue a lawsuit and certified three classes, and that the female players were paid less per game compared to the male players.

According to team co-captain, Megan Rapino, the decision validated their equal-pay campaign. The judge’s decisions essentially rejected the USSF’s argument that there was no discrimination because of the number of female players who earned more than some of the men’s players during that time. However, according to Klausner, there was no case law to support the premise.

The USSF has argued that the differences in compensation between the men’s and women’s teams was due to varying pay structures in the collective bargaining agreements, which are negotiated by the players on the team. However, according to the lawsuit, the USSF charters more flights for male players, which means that they have more comfortable accommodations and opportunities for rest. The men also experience fewer incidences of lost luggage. This ruling may encourage the USSF and its players to revisit efforts to reach an out-of-court resolution.

The USSF’s president said that they are very committed to resolving the matter in a way that is fair. A spokesperson for the female players said that they are happy that the court has recognized the USSF’s discrimination against female players. It is a major step in the right direction in the fight to achieve equal pay. One of the classes is seeking an injunction to prevent future discrimination, and a second class looks to obtain back pay and punitive damages, both of which fall under Title VII of the Civil Rights Act.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green P.C. Advocate for Victims of Gender Discrimination

If you were treated unfairly because of your gender, the Philadelphia employment lawyers at Sidkoff, Pincus & Green P.C. will work tirelessly to investigate the details of your case and ensure that your legal rights are protected. Our skilled legal team will not stop fighting for you until you are completely satisfied. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Located in Philadelphia, we serve clients throughout Pennsylvania and New Jersey.

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NLRB Rule Does Not Recognize Graduate Students as Employees

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Philadelphia employment lawyers assist clients with NLRB employment issues.Graduate students often teach classes and conduct valuable research while earning an advanced degree. However, according to a proposed rule by the National Labor Relations Board (“NLRB”), graduate students are not considered employees, meaning they do not have the right to unionize. Graduate students from leading private institutions across the country have mobilized to fight for unionization to secure higher wages, better benefits, and protection for workers to help deal with sexual harassment and discrimination complaints. If passed, the rule would undercut those efforts.

According to the professor of labor and employment law at Cornell University and general counsel for the American Association of University Professors, the current NLRB is made up of mostly conservative board members who happen to be extremely political and intent on overruling decisions made by previous administrations that expanded employee rights to unionize. According to the professor, the NLRB made these decisions on a case-by-case basis in the past, but that appears to be changing.

Is Graduate Work Considered Work or Education?

At the heart of the argument is whether the teaching and research that graduate students conduct is considered work, or if it is part of their continued education. In 2016, the NLRB decided that Columbia students who were paid to teach and conduct research were considered employees and had the right to unionize. Prior to that, there was some back and forth among NLRB members, which impacted students’ rights to unionize. Prior to the Columbia decision, representatives from nine prestigious universities argued that graduate students have an academic relationship with the university, rather than an economic one. However, the NLRB ruled that graduate students could have a dual status of economic and academic.

Following the Columbia decision, students have come together to form unions at several private universities such as Harvard University, Brown University, Yale University, the University of Chicago, and several others voting in favor of unionization. Graduate students who are currently negotiating for employee status are unsure about how the proposed rule will impact their efforts. If the rule is passed, students have vowed to continue to fight for unionization.

Students at the University of Chicago, Yale University, Boston College, and the University of Pennsylvania sent petitions to the NLRB but withdrew them out of fear that Trump-appointed members would issue an anti-union decision. According to the executive director of the National Center for the Study of Collective Bargaining in Higher Education and the Professions at Hunter College, it is Congress that has the authority to decide employment status, but the NLRB rule seems to be taking over that authority.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green, P.C. Assist Clients with Employment Issues

If you are a graduate student at a college or university, and your employment status prevents you from being able to unionize, contact the Philadelphia employment lawyers at Sidkoff, Pincus & Green P.C. Protecting your legal rights is our top priority and we will ensure that you receive the financial compensation to which you are entitled. To schedule an initial consultation, call us today at 215-574-0600 or contact us online. Located in Philadelphia, we serve clients throughout South Jersey, Pennsylvania, and New Jersey.

Supreme Court to Decide on Racial Bias Lawsuit Against Comcast

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Philadelphia business lawyers represent clients facing a racial bias lawsuit.Byron Allen, owner of Entertainment Studios Network (ESN)—an African American-owned media company—filed a discrimination lawsuit against Comcast, alleging that the telecommunications giant refused to carry any of the network’s channels due to racially discriminatory practices. A federal court initially dismissed the claims. The 9th Circuit Court of Appeals deemed the lawsuit legitimate after Allen appealed the initial decision. Comcast appealed the decision, which ultimately brought the case to the Supreme Court.

According to Allen, Comcast had assured him that his channels were being considered for carriage, and that they were on the “short list” for new channels. However, rather than follow through with that assurance, Comcast moved forward with over 80 lesser-known channels, all of which were owned by caucasians. Comcast characterized the claims as “outlandish” and that the decision to launch the other channels had nothing to do with race.

The key issue that the Supreme Court will be considering is whether there is enough evidence of racial discrimination to allow the lawsuit to proceed. Allen claims that Comcast is in violation of Section 1981 of the Civil Rights Act, which guarantees racial equality in a number of domains, including business. The 9th Circuit Court of Appeals in San Francisco opined that ESN only had to prove that discrimination was a motivating factor in Comcast’s decision regarding ESN programming. However, Comcast argued that Congress allowed “motivating factor” discrimination claims under the Title VII of the Civil Rights Act, but purposely did not include a similar provision to Section 1981. ESN countered by arguing that Congress added the provision to Title VII to protect discrimination victims, and that this should not mean Congress planned to limit civil rights claims under Section 1981.

Philadelphia Business Lawyers at Sidkoff, Pincus & Green P.C. Represent Clients Alleging Discriminatory Business Practices

If you have questions about what you suspect is racially discriminatory conduct, you are urged to contact the Philadelphia business lawyers at Sidkoff, Pincus & Green P.C. at your earliest convenience. Our skilled legal team will thoroughly review your case and determine whether your civil rights have been violated. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our office is conveniently located in Philadelphia, where we represent clients from South Jersey, Pennsylvania, and New Jersey.

Judge Denies Philadelphia Man’s Lawsuit Against Domino’s Over Racial Slur

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Philadelphia business litigation lawyers will fight for your rights against racial discrimination.A Philadelphia resident filed a lawsuit against Domino’s Pizza after a Domino’s employee allegedly directed a racial slur at him during a confrontation in July of 2017. The customer had complained that he received a pizza via delivery that was burnt. He drove to the restaurant to return the pizza and request a refund. The situation became heated after the customer took a picture of the employee, who refused to give the customer his refund unless he agreed to delete the photo. The employee claimed that having her picture taken was against her religion. As the argument escalated, the Domino’s employee allegedly directed an offensive racial slur at the customer. A Pennsylvania Superior Court judge ruled that, while offensive, a racial slur is not enough to warrant a lawsuit.

Ruling Based on 1985 Precedent

The initial lawsuit claimed that Domino’s was negligent in the way it hired, trained, and supervised its employees. The customer claimed that the racial slur directed at him caused emotional distress. Due to a precedent that was established in 1985 in the Pennsylvania Superior Court, which ruled that an individual can only be held liable for emotional distress if the individual’s conduct is extreme and outrageous, the initial lawsuit was dismissed.

The precedent is based on an incident involving an altercation between a department store employee and a shopper, where the employee reportedly directed the n-word at the shopper. The ruling states that an individual cannot be held liable for mere insults, threats, and other indignities or trivialities. Until legal and societal changes occur, plaintiffs must be expected to accept a certain degree of offensive, inconsiderate, or unkind acts. The law cannot intervene every time someone’s feelings are hurt.

The Domino’s customer appealed after the initial lawsuit was dismissed, claiming that the 1985 ruling was outdated. While the Pennsylvania Superior Court made it clear that it does not condone such offensive and derogatory language, the appeal was denied.

Philadelphia Business Litigation Lawyers at The Law Office of Sidkoff, Pincus & Green P.C. Handle a Range of Legal Matters

If you suffered emotional distress, financial harm, or were injured in any way as a result of racial discrimination in the workplace, you are urged to contact the Philadelphia business litigation lawyers at The Law Office of Sidkoff, Pincus & Green P.C. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are located in Philadelphia, where we represent clients in South Jersey, Pennsylvania, and New Jersey.

Supreme Court Rejects Lawsuit Challenging Trans-Friendly Restroom Policy

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Philadelphia local counsel advocate for LGBTQ & trans-friendly restroom policy.In the case of Doe v. Boyertown Area School District, the Alliance Defending Freedom, a conservative legal organization, filed a lawsuit on behalf of an anonymous group of students lead by “Joel Doe” and his parents. The lawsuit claimed that Doe and a group of students who attended Boyertown Area High School felt uncomfortable sharing a restroom with a transgender student. The students also argued that the mere presence of a transgender individual in a single-space area – like a restroom – threatened their health and safety. The U.S. Supreme Court declined to hear the case.

By refusing to hear the lawsuit, the ruling by the 3rd U.S. Circuit Court of Appeals stands, which means that transgender students may use the restroom that corresponds to their gender identity. According to Appeals Court Judge Theodore McKee, the Boyertown Area School District created a policy that respected the unique needs of transgender students. This starts with allowing them to access spaces that match their gender identity.

Boyertown’s Policy Does Not Violate the Rights of Other Students

The lower court ruled that allowing transgender students in sex-segregated schools did not violate the rights of students who are cisgender, or whose own gender experiences correspond to their birth sex. In addition, it does not violate their rights under Title IX of the Education Amendments Act of 1972. According to the law, schools may provide single-sex bathrooms that are comparable to other single-sex facilities, but it is not mandatory. Boyertown’s current policy also states that a student may use gender-neutral or single-user restrooms if they would rather not use the shared facilities.

Doe and the other students said that the presence of transgender students in bathrooms made them uncomfortable. They further argued that the current policy is a form a sexual harassment. The American Civil Liberties Union (ACLU) got involved with the case to support the Pennsylvania Youth Congress, which is a group of LGBTQ leaders and youth organizations. The ACLU also intervened on behalf of a transgender student who had attended Boyertown Area Senior High School during the previous year. According to a senior staff attorney with the ACLU’s LGBT & HIV Project, the outcome of the lawsuit is a tremendous victory for transgender students.

Philadelphia Local Counsel at Sidkoff, Pincus & Green P.C. Advocate for Transgender Rights

If your civil rights have been violated because of your LGBTQ status, Philadelphia local counsel at Sidkoff, Pincus & Green, P.C. will protect your rights, including your right to use the restroom that corresponds to your gender identity. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are located in Philadelphia, where we represent clients in South Jersey, Pennsylvania, and New Jersey.

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Pregnancy Discrimination at Amazon

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Philadelphia employment lawyers advocate for the rights of pregnant workers.Federal and state laws prohibit employers from discriminating against employees because of a number of protected characteristics, including pregnancy. The Pregnancy Discrimination Act mandates that any decisions related to hiring, firing, promotion or demotion, transfer, salary, or benefits cannot be based on an employee’s pregnancy status. Online retailer Amazon has recently come under fire for alleged pregnancy discrimination, facing seven lawsuits in the past eight years.

Amazon is a vast company of more than 600,000 employees that has built its success on productivity. With its guarantee of two-day shipping for Prime customers – recently reduced to one day – the company’s fulfillment centers operate at a fast pace and demand that workers reach high packing quotas. Critics of the company say that this productivity often comes at the expense of employees’ well-being.

Pregnant Workers Penalized for Reduced Productivity

Workers in Amazon’s fulfillment centers often work 10-hour days, most of which is spent on their feet; and they are frequently moving heavy objects. They are typically allotted 30 minutes each shift for non-work tasks, such as going to the restroom. Any additional time could affect an employee’s rate, a metric used to measure their productivity. According to the lawsuits, pregnant employees, who need some accommodations for their condition, were disproportionately affected by these policies.

In the most recent case, an employee at Amazon’s Golden State Fulfillment Center in California was fired two months after informing management that she was pregnant. Her lawsuit alleges that, during those two months, her supervisors chastised her for taking too many bathroom breaks and reducing her productivity. Another employee filed a lawsuit after requesting not to climb ladders or lift boxes over 20 pounds, at the advice of her doctor. Her managers put her on unpaid leave for over a month while they claimed they were trying to accommodate her requests; when she returned, no accommodations had been made, and she was terminated a month later. Two others were fired after taking sick days during their pregnancies.

Amazon released a statement refuting the allegations in the lawsuits, saying that they would not terminate an employee due to pregnancy. The company claims that they accommodate work restrictions for pregnant employees based on their individual needs, and that they do not keep tabs on employees’ bathroom breaks. The statements made in the lawsuits tell a very different story, in which managers stood waiting for employees to return from breaks and rejected doctors’ notes requesting accommodation. Six of the seven lawsuits were settled out of court.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green P.C. Advocate for the Rights of Pregnant Workers

Employers are required by law to make reasonable accommodations for workers’ medical conditions, including pregnancy. If you have been subjected to pregnancy discrimination in the workplace, call the law offices of Sidkoff, Pincus & Green P.C. We will thoroughly review the facts of your case and work to ensure that your rights are protected. With offices located in Center City, Philadelphia, we represent victims of workplace discrimination throughout Pennsylvania and New Jersey. Call us today at 215-574-0600 or contact us online to discuss your case with a Philadelphia employment lawyer.

Dismissing Federal Lawsuit Does Not Delay Statute of Limitations

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Philadelphia appellant lawyers assist clients with the appeals for statute of limitations.In the case of Jaiden Buchan v. The Milton Hershey School, the Pennsylvania Superior Court recently ruled that the clock does not stop on the statute of limitations for making a claim in state court, simply because someone voluntarily withdraws a lawsuit. Buchan filed a complaint against the school in December of 2016, alleging that the school had violated the Americans with Disabilities Act (ADA) and the Fair Housing Act. She voluntarily withdrew her lawsuit against the school on June 19, 2017. The plaintiff filed a writ of summons in July of 2017, but the court ruled that the voluntary withdrawal of her lawsuit was not the same as a federal court dismissing the case for lack of jurisdiction.

According to Judge Alice Beck Dubow, since Buchan filed an action in federal district court, and then voluntarily dismissed it, this does not toll the statute of limitations. The Dauphin County Court of Common Pleas dismissed the case in April 2018, saying that since there was no pause caused by the federal suit, the window to file an action closed when Buchan turned 20, which was six months before she filed the Complaint in state court.

Claims Made by Buchan

Buychan claimed that the school neglected her mental health issues, unfairly punished her for getting a tattoo, and accused her of starting a fire at the school, which resulted in her being expelled from the school. She initially filed claims in the federal court in December 2016, alleging that the school intentionally inflicted emotional distress, as well as other violations of the ADA, including breach of fiduciary duties of care and malicious prosecution. However, Buchan withdrew the suit in June of 2017.

Later that year, Buchan filed a writ of summons in Dauphin County, and two months later she filed a complaint alleging negligence, breach of duties of care and good faith, emotional distress, and malicious prosecution. The state court dismissed the case, saying that it was time-barred. Buchan appealed, arguing that according to the Title 42, Section 5103 of Pennsylvania’s Consolidated Statutes, the statute of limitations is tolled when a case is dismissed for lack of jurisdiction. Because she withdrew her case, Buchan argued that she “rendered the federal court without federal jurisdiction.” As a result, her federal suit should have stopped the clock. In addition, she argued that the Title 28, Section 1367 of the U.S. Code gave her 30 days to refile in state court if a federal court did not exercise supplemental jurisdiction. According to Buchan, less than 30 days had passed between the voluntary dismissal and the first filing in the state lawsuit. Section 1367 included voluntarily dismissed cases.

The Superior Court ruled that the “voluntarily dismissed” part of Section 1367 only applies to claims that are not being considered by the federal court under supplemental jurisdiction. Judge Dubrow wrote that the language in the Section 1367 does not apply to Buchan’s case because she voluntarily dismissed all of the state law claims she asserted in her federal complaint under supplemental jurisdiction.

Philadelphia Appellant Lawyers at Sidkoff, Pincus & Green, P.C. Assist Clients with the Appeals Process

The Philadelphia appellant lawyers at Sidkoff, Pincus & Green, P.C. have extensive experience handling various types of appeals, including issues relating to employment discrimination, due process, and constitutional law, among others. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are conveniently located in Center City Philadelphia, where we serve clients from Southeastern Pennsylvania, South Jersey, and New Jersey.