Levitt v. Board of Educ., City of Newark

In Levitt v. Board of Educ., City of Newark, 197 N.J. Super. 239, 484 A.2d 723 (App.Div.1984), the Court stated that the Commissioner of Education could fashion remedies, including ordering prejudgment interest on a teacher's back-wages in a tenure dispute, although not specifically so authorized by statute. Our dictum in Levitt was predicated on the finding that the Commissioner was endowed with the ancillary power to impose such liability in order to fully execute his statutory responsibilities under the school laws. Ibid.