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N.J. Top Court Upholds COVID-19 Benefits for Deceased Teacher’s Spouse as ‘Essential’

07 Feb, 2026 Frank Ferreri

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Case File

Because teachers were deemed essential employees for purposes of the COVID-19 pandemic in New Jersey, a teacher's contraction of COVID-19, which led to her death, was work-related and fully compensable. Simply Research subscribers have access to the full text of the case.

Case

Amato v. Township of Ocean School District, A-31-24 (N.J. 12/11/25)

What Happened?

At the onset of the COVID-19 pandemic, New Jersey's Office of Emergency Management adopted federal essential worker guidelines, which covered teachers. Additionally, the state's health department promulgated two COVID-19 vaccination plans, which identified teachers as essential employees.

A teacher died of respiratory failure as a result of COVID-19, and her husband filed a workers' compensation claim. A judge of compensation determined that the teacher was an essential employee and that there was, therefore, a rebuttable presumption that her contraction of COVID-19 was work-related.

The Appellate Division affirmed, prompting the school district to appeal to the New Jersey Supreme Court.

Rule of Law

Under New Jersey law, "essential employee" means an "employee in the public or private sector who, during a state of emergency" is "deemed an essential employee by the public authority declaring the state of emergency."

What the New Jersey Supreme Court Said

The New Jersey Supreme Court affirmed the Apellate Division's ruling that the teachers were deemed essential employees by the public authority declaring the state of emergency through the governor's delegation of the responsibility to protect the public to the New Jersey Office of Emergency Management's adoption of the federal list of essential employees, which included teachers.

Additionally, teachers were deemed essential employees through the governor's delegation of authority to New Jersey Department of Health's issuance of two separate vaccination plans deeming teachers to be "essential employees."

Verdict: Affirmed.

Takeaway

Under two legal bases, teachers are considered essential employees when it comes to COVID-19 and workers' compensation benefits.

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    About The Author

    • Frank Ferreri

      Frank Ferreri, M.A., J.D. covers workers' compensation legal issues. He has published books, articles, and other material on multiple areas of employment, insurance, and disability law. Frank received his master's degree from the University of South Florida and juris doctor from the University of Florida Levin College of Law. Frank encourages everyone to consider helping out the Kind Souls Foundation and Kids' Chance of America.

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