In a lengthy set of opinions, the New Jersey Supreme Court has said it is unwilling, by a vote of 5-2, to impose a “non-delegable duty” upon a nonprofit residential facility to protect its residents from the intentional criminal acts of its employees. The majority said it would be an inappropriate form of absolute liability for the organization. It also held that no reasonable jury could have found that an employee’s act of throwing scalding water on a resident was within the scope of her employment responsibilities and affirmed a grant of summary judgment in favor of the organization. The issue arose in a case involving Devereux Foundation, a national provider of services to persons with...