Law & Justice
Federal Appeals Court Orders Reconsideration of New Jersey Divorce Dispute, Keeps $91,500 Penalty
A New Jersey man was ordered to pay his former wife $91,500 after he refused to provide a religious divorce document required under Jewish law. The couple’s civil marriage ended in October 2020, but their settlement agreement required them to follow the decision of an Orthodox Jewish rabbinical court. Ava Renee Satz asked Allen Jeffrey Satz to appear before a beis din in New City, New York, to obtain a get, the religious divorce document. Allen initially declined to participate. In February 2023 the beis din ruled in Ava’s favor, directing Allen to pay $150 for each day he failed to provide the get and allowing public shaming measures to continue until he complied. Ava later asked the New Jersey Superior Court to enforce the decision. The trial court ordered Allen to pay $91,500 as a penalty for failing to follow the rabbinical court’s ruling. Allen challenged the penalty, arguing that the arbitration proceedings violated their settlement agreement and that the rabbinical court had no authority to impose financial penalties. He also claimed the ruling defamed him and that one arbitrator’s signature was forged. The trial court rejected his challenge, noting that the settlement agreement permitted monetary penalties and that Allen had not identified a false statement to support his defamation claim. It also found that he had missed the 120‑day deadline for challenging an arbitration decision under New Jersey law; his application was filed seven months late. The New Jersey Appellate Division upheld the decision in July 2025, and the state Supreme Court declined to review the matter in November 2025. Allen had still not provided the get by that time.
Allen subsequently filed a separate lawsuit in the U.S. District Court for the District of New Jersey, initially under a federal civil rights law and later adding 13 claims under state and federal laws. His allegations included violations of constitutional rights, invasion of privacy, breach of the settlement agreement, interference with parental rights, and intentional infliction of emotional distress. A magistrate judge questioned whether the federal court could hear the case because several allegations challenged decisions already made by New Jersey courts. The district court accepted the recommendation and dismissed the complaint. Allen appealed to the Third Circuit. The appellate court found that the lower court had treated all his allegations as one dispute without examining them separately. It noted that some claims directly challenged the state court’s decision to impose the $91,500 penalty and could therefore be barred, while other allegations appeared to involve separate disputes. The court specifically mentioned the intentional infliction claim as an example that required individual examination. The Third Circuit overturned the dismissal and returned the case to the district court, directing that the claims be examined separately to determine which, if any, can proceed.