State Farm Mut. Auto Ins. Co. v. State

In State Farm Mut. Auto Ins. Co. v. State, 124 N.J. 32, 45-46, 590 A.2d 191 (1991), the New Jersey Supreme Court held that the plaintiff insurance companies did not have a contractual relationship which the State of New Jersey could impair. To the contrary, the Court noted "like all regulatory schemes, the JUA was potentially transient, subject to change at any time by the Legislature that created it. In a highly regulated business such as insurance, participants cannot credibly assert that they had any vested right or contractual expectation in the indefinite continuance of the JUA scheme." State Farm, supra, 124 N.J. at 64-65, 590 A.2d 191. The Court further held that even if the Fair Act impaired plaintiffs' contractual relationships, "it would nonetheless be justified in this instance because the Fair Act addresses a significant and legitimate public purpose, imposing reasonable conditions that are related to appropriate governmental objectives." Id.