In Foldi v. Jeffries, 93 N.J. 533, 546-47, 461 A.2d 1145 (1983), the Supreme Court preserved the doctrine of New Jersey parental immunity in cases involving the negligent exercise of parental authority or provision of customary child care. However, if the parents' behavior is willful and wanton, the parental immunity doctrine does not apply. Id. at 547, 461 A.2d 1145. In Foldi, the Court invoked the doctrine, barring an action against parents who negligently supervised their child, resulting in the child's wandering away from her residence over to a neighbor's residence where she was bitten on the face by a dog. Id. at 535, 461 A.2d 1145. The Court carved out an exception to the doctrine where the parent's failure to supervise his or her children is "willful or wanton," id. at 549, 461 A.2d 1145, that is: It must appear that the defendant with knowledge of existing conditions, and conscious from such knowledge that injury will likely or probably result from his conduct, and with reckless indifference to the consequences, consciously and intentionally does some wrongful act or omits to discharge some duty which produces the injurious result. Id. at 549, 461 A.2d 1145 (quoting McLaughlin v. Rova Farms Inc., 56 N.J. 288, 305, 266 A.2d 284 (1970)). The Court in Foldi barred the daughter's suit because it found that the mother's lack of supervision "was, at worst, merely negligent." Id. 93 N.J. at 550, 461 A.2d 1145.