A New Jersey man’s refusal to give his former wife a religious divorce has led to a $91,500 penalty and a lengthy legal dispute. Although their marriage officially ended in 2020, the couple continued to disagree over a religious document required to complete their divorce under Jewish law.The dispute returned to court after Allen Jeffrey Satz challenged the dismissal of a lawsuit he had filed against his former wife, Ava Renee Satz. On Thursday, the US Court of Appeals for the Third Circuit ruled that the lower court must reconsider parts of his complaint instead of rejecting all his claims together.According to the judgement, the appeals court sent the case back for further examination. However, it did not cancel the $91,500 penalty imposed earlier by a New Jersey state court or decide whether Allen’s allegations against Ava were valid.The couple began divorce proceedings in 2018 after 12 years of marriage. Their marriage officially ended under New Jersey law in October 2020. However, their settlement agreement also required them to follow the decision of an Orthodox Jewish rabbinical court on religious matters.
Dispute over religious divorce
Ava wanted Allen to provide a document known as a get, which is required to complete a divorce under Orthodox Jewish religious law. She asked him to appear before a beis din, an Orthodox Jewish rabbinical court in New City, New York.Allen initially did not participate in the proceedings. Ava then approached the New Jersey Superior Court, asking it to enforce their settlement agreement.Allen eventually signed an arbitration agreement, accepting the rabbinical court’s rules and agreeing to follow its decision. These rules also allowed the court to proceed in his absence and impose penalties if he failed to comply.In February 2023, the beis din ruled in Ava’s favour. It directed Allen to pay $150 for every day he failed to provide the get. The court also allowed public shaming measures to continue until he complied.Ava later asked the state court to enforce this decision. The trial court ordered Allen to pay her $91,500 as a penalty for failing to follow the rabbinical court’s ruling.
Allen’s challenge to the penalty
Allen tried to get the arbitration decision cancelled. He argued that the proceedings violated their settlement agreement and that the rabbinical court had no authority to impose financial penalties.He also claimed that the ruling defamed him and suggested that one of the arbitrators’ signatures had been forged.The trial court rejected his request. It said the settlement agreement allowed monetary penalties and that Allen had not identified a false statement to support his defamation claim.The court also found that he had missed the 120-day deadline for challenging an arbitration decision under New Jersey law. His application had been filed seven months late.The New Jersey Appellate Division upheld the decision in July 2025. The state’s Supreme Court later declined to review the matter in November 2025. Allen had still not given Ava the religious divorce document by that stage.
Why the federal appeals court reopened the case
Allen subsequently filed a separate lawsuit against Ava in the US District Court for the District of New Jersey. He initially brought the case under a federal civil rights law and later expanded it to include 13 claims under state and federal laws.His allegations included violations of his constitutional rights, invasion of privacy, breach of their settlement agreement and interference with his parental rights. He also accused Ava of intentionally causing him emotional distress.A magistrate judge questioned whether the federal court could hear the case because several allegations challenged decisions already made by New Jersey courts. The district court accepted the recommendation and dismissed his complaint. Allen appealed that decision to the Third Circuit.The appeals court found that the lower court had treated all his allegations as one dispute without examining them separately. It said some claims directly challenged the state court’s decision to impose the $91,500 penalty and could therefore be barred.However, other allegations appeared to involve separate disputes between Allen and Ava. The judges specifically mentioned his claim of intentional infliction of emotional distress as an example.The court said these claims needed individual examination before deciding whether they could proceed.The Third Circuit therefore overturned the dismissal and returned the case to the district court. The lower court will now have to examine the claims separately and decide which, if any, can move forward.