A bombshell new lawsuit has just been filed in Ocean County — and it tells a very different story than the one Jackson Township officials sold to the public just weeks ago, a FAA News investigation reveals.
Back in February, Mayor Jennifer Kuhn and the Township Council proudly rolled out Ordinance 2026-06, touting it as a major step forward for tenant protections.
In an “approved” press release, Township officials claimed the ordinance was:
> “legislation that not only complies with state law but also reflects the voices of residents who sought relief and clarity.”
But according to a newly filed complaint, the “voices of residents” may have actually been something else entirely:
👉 The very individuals who drafted the law — for their own financial benefit.
THE LAWSUIT: WHO FILED IT AND WHAT IT SEEKS
The lawsuit — filed by multiple manufactured housing community owners including UMH Properties and others — was brought by Lori C. Greenberg, Esq. of Lori C. Greenberg & Associates .
It doesn’t just challenge the ordinance.
It attacks the entire process behind it — and names individual defendants.
The suit seeks:
A declaration that Ordinance 2026-06 is unconstitutional
An injunction voiding and blocking enforcement of the ordinance
Compensatory and punitive damages
Attorney’s fees and costs
Monetary penalties against individual defendants, including Joseph and Frank Sullivan
THE ALLEGATION: INSIDERS DRAFTED THE LAW TO CONTROL THEIR OWN RENT
At the center of the lawsuit are two politically connected figures:
Joseph Sullivan — Chairman of the Jackson Rent Leveling Board and Executive Director of the Manufactured Home Owners Association of NJ (MHOA-NJ)
Frank Sullivan — Member of the Rent Leveling Board and Vice President of MHOA-NJ
According to the complaint:
> Joseph Sullivan and Frank Sullivan “drafted the ordinance to benefit themselves” and were “active proponents” of both the ordinance and related state legislation.
The suit alleges both men:
Live in manufactured home communities
Personally pay rent subject to the ordinance
Participated in drafting and promoting the law
Stood to directly benefit financially from its passage
In plain English:
👉 The people writing the rent law were allegedly writing it to limit their own rent increases.
CONFLICT OF INTEREST? THE SUIT SAYS YES — LOUDLY
The complaint goes even further, alleging violations of:
New Jersey Local Government Ethics Law (N.J.S.A. 40A:9-22.1 et seq.)
Common law conflict-of-interest doctrine
Federal civil rights law under 42 U.S.C. §1983
Among the most explosive claims:
The Sullivans failed to recuse themselves despite personal financial interest
They used their official roles to influence the ordinance
The process lacked a neutral decision-maker
The ordinance was designed to transfer economic value from landlords to a specific class — including themselves
The lawsuit explicitly seeks fines and penalties against the Sullivans under state ethics law.
THE ORDINANCE ITSELF: TARGETING ONE GROUP
The lawsuit claims Ordinance 2026-06:
Caps rent increases for manufactured home communities at 2.5%
While other rental properties can increase up to 4.25%
Ignores a state statute allowing 3.5% increases
Eliminates fees and revenue streams unique to these properties
Imposes restrictions that allegedly make the properties financially unviable
The result, according to plaintiffs:
👉 Manufactured home community owners are being singled out and economically squeezed — while a specific group of tenants benefits.
NO DATA, NO JUSTIFICATION?
In perhaps one of the most eyebrow-raising allegations:
The Township allegedly admitted — in response to an OPRA request — that no documents exist supporting the decision to impose the stricter 2.5% cap.
No studies.
No financial analysis.
No justification.
Yet the ordinance passed anyway.
FROM “RESIDENT VOICES” TO “INSIDER CONTROL”?
This is where the contrast becomes impossible to ignore.
👉 Kuhn’s version:
A thoughtful ordinance reflecting community input and complying with state law.
👉 The lawsuit’s version:
A law drafted and driven by insiders with direct financial interests, pushed through without transparency, and designed to benefit a select group.
Those are not two slightly different interpretations.
Those are two completely different realities.
THE LEGAL CLAIMS — ALL OF THEM
The complaint doesn’t hold back. It asserts:
Prerogative Writ (challenge to municipal action)
Regulatory and substantive taking of property
Equal protection violations
Due process violations
No legitimate public purpose
Federal civil rights violations (42 U.S.C. §1983)
Ethics law violations
Common law conflict of interest
And the remedy?
👉 Kill the ordinance.
👉 Enjoin enforcement.
👉 Award damages.
👉 Penalize the individuals involved.
THE BIGGER PICTURE
This lawsuit doesn’t just challenge a rent ordinance.
It raises a far more serious question:
Was Jackson Township policy driven by neutral governance — or by insiders regulating their own financial obligations?
And if the allegations are true:
Who really wrote the law?
Who benefited from it?
And why was the public told a very different story?
BOTTOM LINE
What was sold as “resident-driven reform” is now being challenged as something else entirely:
👉 An insider-driven scheme to control rent — for the benefit of those writing the rules.
The courts will ultimately decide the legality.
But one thing is already clear:
There is far more to this story than the Township’s press release ever revealed.
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