The New Jersey Supreme Court has ruled that paramedics who provided advanced life support to a young man who later suffered a severe anoxic brain injury are entitled to statutory immunity from civil liability, closing out a case that tested exactly how strictly the state’s paramedic immunity law should be interpreted. In Jari Almonte versus Township of Union, decided June 25, 2026, the Court held that the paramedics acted under the direct orders of a supervising physician conveyed through live voice communication, meeting the specific statutory requirements that trigger immunity under New Jersey law.
The case traces back to an emergency involving Jeremy Almonte, who began convulsing after falling while running, prompting his mother to call for emergency medical assistance. Atlantic Ambulance paramedics responded and established phone contact with Dr. Niti Sharma, a licensed physician working in the emergency department at Overlook Medical Center. During that first call, Dr. Sharma instructed the mobile intensive care paramedics to administer Valium. As Almonte’s heart rate continued declining, the paramedics called Dr. Sharma a second time and received further instructions, including directions to intubate Almonte in an effort to open his airway. The ambulance reached the hospital following an unsuccessful first intubation attempt, and paramedics made a second and then a third attempt, with the third ultimately proving successful before Almonte was brought into the hospital.
By the time he reached the Trauma Center, Almonte had gone into cardiac arrest. Medical staff there reintubated him and successfully resuscitated him, restoring his breathing. Almonte was ultimately discharged from the hospital in September 2012, but he had been diagnosed with anoxic brain injury along with a number of significant, lasting physiological effects. His family subsequently filed a lawsuit against Atlantic Ambulance Corporation and the responding paramedics, alleging that negligent, careless, reckless, and willful conduct had caused his injuries.
The defendants moved for summary judgment, arguing that New Jersey’s paramedic immunity statute shielded them from liability because they had rendered advanced life support services in accordance with the state’s Emergency Medical Services Act. The trial court agreed and dismissed the family’s complaint, and the Appellate Division subsequently affirmed that decision. The Supreme Court then granted certification specifically limited to the narrow legal question of whether the paramedics qualified for immunity under N.J.S.A. 26:2K-14, a determination that depends entirely on whether they acted in accordance with the underlying statute.
Writing for a unanimous Court, Justice John Jay Hoffman held that the paramedics had indeed acted under Dr. Sharma’s orders, and that those orders were conveyed through direct voice communication as the statute requires, entitling the defendants to immunity based on the statute’s plain language and its underlying legislative intent. The Court’s reasoning rested heavily on the specific text of New Jersey’s paramedic immunity framework. Under N.J.S.A. 26:2K-10, a mobile intensive care paramedic may perform advanced life support services provided they maintain direct voice communication with, and take orders from, a licensed physician. A separate provision, N.J.S.A. 26:2K-14, states that no paramedic shall face civil liability for an act or omission committed while rendering advanced life support services in good faith and in accordance with the statute, a protection broad enough that a paramedic can act negligently and still remain immune from civil damages under the law.
The Court found that the specific interventions performed on Almonte, intravenous administration of muscle relaxant and sedative medications, continuous heart rate monitoring through an electrocardiogram, and endotracheal intubation using an adjunctive ventilation device, fell squarely within the statutory definition of advanced life support services. The justices also concluded that the paramedics had satisfied the statute’s direct voice communication requirement through their two mobile phone calls with Dr. Sharma, even though a considerable stretch of time passed between that second call and the ambulance’s arrival at the hospital.
That timing question became a central point of dispute in the case. The plaintiffs argued that the paramedics’ roughly seventeen minutes of silence while attempting intubation after their second call to Dr. Sharma was inconsistent with the statutory requirement to maintain direct voice communication, and that a significant change in Almonte’s condition, such as his declining heart rate or the ambulance’s arrival at the hospital, should have required the paramedics to reestablish contact with the supervising physician. The Court rejected that argument directly, noting that the Legislature never specified any particular cadence or frequency for direct communication with a physician, nor did it establish specific criteria dictating when paramedics must recontact medical command in response to a changing patient condition. The justices reasoned that interpreting the statute to require continuous or predetermined communication would produce an outcome plainly at odds with the Legislature’s actual intent in expanding paramedic immunity within emergency medical contexts, since it would force paramedics responding to genuine emergencies and treating critically ill patients under intense time pressure to maintain an arbitrary communication schedule, a requirement that would undermine the very purpose behind granting paramedics this kind of legal protection in the first place.
The Court also addressed the plaintiffs’ reliance on a separate state regulation, N.J.A.C. 8:41-8.5(b)(1), which provides that a difficult intubation should not delay a patient’s transportation. The justices found that reliance misplaced, concluding that even assuming the regulation held any relevance to the broader immunity analysis, despite the paramedic immunity statute itself making no reference to it, that regulation ceases to apply once contact has already been made with the supervising medical command physician.
The ruling offers genuine clarity for how New Jersey’s paramedic immunity statute applies in fast moving, high stakes emergency medical situations, confirming that paramedics who establish direct voice contact with a supervising physician and act under that physician’s orders remain protected from civil liability even when a patient’s condition changes significantly, and even when meaningful time passes before paramedics reestablish contact with that physician. For emergency medical providers across the state, the decision reinforces that New Jersey’s immunity framework is designed specifically to give paramedics room to make rapid, high pressure medical decisions in the field without the looming threat of civil liability shaping every choice they make in the moments that matter most.
