A plaintiff’s attorney hired Sullivan | Simon to help in a personal injury case arising out of a car accident. The plaintiff sought punitive damages because the defendant was drunk at the time of the accident. The defendant moved for partial summary judgment, arguing that punitive damages could not be awarded as a matter of law. The defendant also tried to persuade the Law Division judge by citing an unpublished opinion. Sullivan | Simon handled the plaintiff’s briefing and we found controlling precedent that convinced the judge to deny the motion and allow the plaintiff to pursue punitive damages.