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Zipporah E. Ridley

Associate

ZERidley@mdwcg.com

Portrait of Zipporah E. Ridley

Zipporah is a member of the Professional Liability Department where she focuses her practice on the defense of attorneys, accountants, insurance producers, corporate directors and officers, and financial institutions, among other clients. She previously served as a law clerk at our firm and most recently served as an attorney at the U.S. Equal Employment Opportunity Commission (EEOC).

Further, Zipporah completed a service year with the Jesuit Volunteer Corps., working at the Center for Community Alternatives, where she provided employment services to those who were formerly incarcerated. Upon concluding her service year, she served as a Pro Bono Case Manager at Philadelphia VIP, connecting low-income Philadelphians to volunteer attorneys for civil law matters. 

After working for Philly VIP, Zipporah attended Delaware Law School where she received her Juris Doctorate. She currently serves on the Board of Directors at Spectrum Health Services, Inc., a Federally Qualified Health Center (FQHC). 

Zipporah is admitted to practice in the District of Columbia and the state of New Jersey.

    • Widener University Delaware Law School (J.D., cum laude, 2022)
    • Santa Clara University (B.A., 2017)
    • District of Columbia, 2023
    • New Jersey, 2025
    • Spectrum Health Services, Board Member

Thought Leadership

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Case Law Alerts

U.S. Bankruptcy Court Upholds State Court Decisions

April 1, 2026

On March 10, 2025, the United States Bankruptcy Court, District of New Jersey, reinforced the decisions of the state court and its power to issue final judgments, including sanctions through the dismissal of the adversarial complaint. After years of complex litigation, the state court issued economic sanctions against the plaintiff for multiple offenses, including frivolous litigation and violations of sealing orders. These sanctions included attorney’s fees. The plaintiff failed to pay the sanctions, and they were subsequently entered as judgments, and then recorded as liens on her property. The current action arose after the plaintiff sold the property and noticed the recorded liens, despite the previous court notices. The plaintiff filed an adversary complaint in federal bankruptcy court seeking, a “judicial determination that the lien was fraudulent in origin and of no legal effect,” and sued the attorneys and their firms from the underlying state court matter. All defendants filed a motion to dismiss based on several bases, including: “(1) the Debtor lacks standing to bring the claims asserted in the Complaint; (2) the claims are barred by the Rooker-Feldman doctrine; (3) the claims are barred by collateral estoppel, res judicata, and the entire controversy doctrine; (4) the Complaint fails to state a cause of action; (5) the claims are barred by litigation privilege; (6) the Complaint improperly seeks an advisory opinion.” The court granted the motions to dismiss for multiple reasons. First, the court agreed that the plaintiff did not have standing to pursue a cause of action after the appointment of a trustee. Secondly, the court found that the claims were barred by the Rooker-Feldman doctrine because she sought to have the bankruptcy court rule that judgments entered by the state courts were invalid. The court found that they lacked the jurisdiction to consider the sanctions and their legitimacy under Rooker Feldman. Subsequentially, the court dismissed the matter because it was already litigated in state court, therefore issue preclusion barred the relitigating of the issue. Additionally, it was determined that the plaintiff failed to state a claim because she made conclusory statements, but did not make factual allegations to support the claims. Lastly, the court dismissed the plaintiff’s claim because it was impermissible for federal courts to give advisory opinions based on the hypothetical statement of facts.

Legal Updates for Lawyers' Professional Liability

New Jersey Defines When Attorneys Owe Duties to Non-Client

March 1, 2026

Christakos v. Boyadjis, 262 N.J. 447 (2026) When does an attorney owe a non-client a duty of care? And when can that non-client bring forth an action for legal malpractice? Christakos v. Boyadjis, 262 N.J. 447 (2026), undertakes these questions and considers the appropriate standard. In the present matter, the plaintiffs brought suit against the attorney that prepared the wills of their two family members, alleging legal malpractice. The two plaintiffs were the sister-in-law and niece to the decedents. The decedents were brothers and, in 2003, they executed mirror image wills, along with completing powers of attorney (POA) documents in 2001. As a result of these documents, the plaintiffs stood to inherit part of the estate, and one plaintiff was attorney-in-fact under the POA. However, the plaintiffs had no knowledge of this or the testamentary documents. In 2017, the brothers sought to make changes to their wills, expressing a strong desire to disinherit their nephew and nieces, wanting to leave their estate to their church and local community members that were supporting them in their advanced age. In 2018, their health began to decline, and the attorney made the final changes to their wills. The will for the first brother was completed in January 2018, leaving everything to the surviving brother, and the alternative residuary was to be split equally between two neighbors, their church, and then their sister-in-law, which is one of the plaintiffs. The other brother was not competent to execute the will and continued to have cognitive decline. This brother executed his will on April 7, 2018, after a home health aide determined that he was in a lucid state and had testamentary capacity. A few days letter, that brother was confirmed to be incompetent and needed a legal guardian appointed. Both brothers died in 2018, and the niece filed two caveats, challenging both wills among other probate actions. In 2020, the plaintiffs sued the attorney for legal malpractice, breach of fiduciary duty, and other claims, arguing that the attorney owed them a duty of care because they were beneficiaries to the brothers' estate. After years of motion practice and appeals, the Supreme Court of New Jersey expressly adopted the provisions of Section 51 of the Restatement (Third) of the Law Governing Lawyers to determine when a lawyer owes a duty of care to a non-client. In doing so, the court determined that the standard hinges upon reliance and clear, convincing evidence of intention.

Firm Highlights

Result

No-Cause Jury Verdict Secured in Wrongful Death Trial

We successfully obtained a no-cause jury verdict in a 13-day wrongful death trial. The decedent, a 59-year-old man, was admitted to the emergency room on February 15, 2019, with complaints of abdominal pain, decreased appetite, and constipation, despite the use of laxatives. The patient did not complain of any nausea, vomiting, or diarrhea. He had a significant medical history including diabetes, hypertension, prior coronary artery stenting, morbid obesity (with past gastric bypass surgery), longstanding ventral hernia, and back pain. A CT scan revealed multiple hernias and a potential closed-loop bowel obstruction, leading to a surgery consultation. Our client, an emergency general surgeon, interpreted that the patient did not have a closed loop or any significant obstruction and recommended non-surgical management. The patient was approved to have clear liquids, and had a vomiting incident shortly after, but our client was not notified. The patient was returned to NPO status, and after improving overnight, he was returned to “clears” and additional medical and renal consults were ordered. Our client did not receive any communications from the residents/nurses of any changes in the patient’s condition. On February 18, 2019, two rapid responses were called due to increased heart rate and vomiting. It is believed that the vomiting resulted in aspiration, causing sepsis, ultimately leading to the patient’s death. During the trial, the plaintiff’s sole medical expert highlighted imaging on the wrong hernia, which called into question all of his opinions in the case. We made key objections related to the expert testimony, limiting what the allegations were, and preventing new allegations from being made. After approximately two and a half hours of deliberating, the jury returned a no-cause verdict. 

Thought Leadership

U.S. Supreme Court Decides Key Issue Regarding Interstate Freight Broker Liability

Freight brokers are intermediaries.  They connect shippers of goods with trucking companies that transport those goods.  Freight brokers match a load of freight with a trucking company and oversee the logistics of the transportation. For a number of years there has been a division among the Federal Circuits regarding the potential liability of freight brokers when the trucking companies that they retain for interstate loads are involved in accidents.  At the center of this division was the Federal Aviation Administration Authorization Act of 1994 (FAAAA).  Some Federal Circuit Courts have held that state law negligent hiring claims against freight brokers were preempted by the FAAAA .  Other Federal Circuits Courts have held that even if preemption applied, the “safety exception” in the FAAAA saved state law negligent hiring claims from federal preemption.  On May 14, 2026, the U.S. Supreme Court addressed the conflict in Montgomery v. Caribe Transport II, LLC, et al, No24-1238. In that case freight broker C.H. Robinson selected Caribe Transport to haul an interstate load. The commercial truck driver employed by Caribe Transport allegedly caused an accident and the plaintiff, Montgomery, was seriously injured. Montgomery brought an action against the driver, Caribe Transport and C.H. Robinson. The allegation against C.H. Robinson was that it negligently retained Caribe Transport when it knew, or should have known, that it was an unsafe company. The Seventh Circuit Court of Appeals held that Montgomery’s claims against C.H. Robinson were preempted by the FAAAA. The plaintiff appealed to the U.S. Supreme Court.  The U.S. Supreme Court’s decision focused primarily on the safety exception in the FAAAA.  That provision provides that the FAAAA preemption “…shall not restrict the safety regulatory authority of a State with respect to motor vehicles.” C.H. Robinson argued, as freight brokers historically have, that their function was not “with respect to motor vehicles” because they do not own trucks or employ drivers. They are merely intermediaries, connecting entities who need freight moved with entities who can do that job. Therefore, C.H. Robinson argued that preemption applied, not the safety exception. The U.S. Supreme Court did not accept that argument. The Court focused on the meaning of the phrase “with respect to” in the safety exception. The Court held that it means “referring to”, “concerning” or “regarding”. Therefore, writing for a unanimous Court, Justice Barrett concluded that “[r]equiring C.H. Robinson to exercise ordinary care in selecting a carrier therefore “concerns” motor vehicles—most obviously, the trucks that will transport the goods. So, Montgomery’s negligent-hiring claim falls within the FAAAA’s safety exception, which saves it from preemption.” Justice Kavanaugh, in his concurring opinion, noted the effect this ruling may have on freight brokers and their insurers throughout the country: Importantly, the Court's decision today should not be read to mean that brokers will routinely be subject to state tort liability in the wake of truck accidents. As even plaintiff's counsel stressed, brokers should be able to successfully defend against state tort suits if the brokers have acted reasonably and arranged transportation with reputable trucking companies. Tr. of Oral Arg. 27-29. In plaintiff's counsel's words, the brokers "just have to hire carriers that actually have a reasonable policy," and "the broker is not going to have a problem if it's asking the hard questions of the carrier." Id., at 42, 45. In addition, the proximate-cause requirement in typical state tort law should help protect brokers from excessive liability. Id., at 25. That said, the brokers rightly caution against naivete. In the real world, as the brokers forcefully respond, state tort law can be unpredictable, and the costs to brokers of litigation and insurance may be significant even when brokers prevail in lawsuits. Moreover, the costs of litigation and insurance, as well as the costs of brokers' conducting more substantial inquiries into trucking companies, will cascade through the economy and be paid in part by American consumers in the form of higher prices. The concerns expressed by the brokers are legitimate and weighty. The key point here is that freight brokers can no longer claim they are protected from negligent retention claims by the FAAAA (in cases involving interstate transportation). The challenge will be to determine what is considered ”reasonable efforts” used by brokers when retaining transportation companies. 

blue facade of a hospital sign against blue sky

Result

Defense Verdict in Complex Medical Malpractice Trial

Result

Summary Judgment Secured, Preserving $750,000 in Coverage for Insured in Major Trucking Liability Dispute

Ray Freudiger and Michael A. Roberts (both of Cincinnati) successfully obtained summary judgment on behalf of their client in a coverage dispute arising from a May 19, 2022, motor vehicle accident. A permissive driver operated a box truck for an interstate trucking company and caused severe injuries to two tort victims. Prior to the accident, the insured had procured a commercial auto policy for the trucking company with stated limits of $1,000,000. Following the accident, the insurer initiated a declaratory judgment action asserting that only reduced bodily injury limits of $25,000/$50,000 applied and later counterclaimed, alleging it would not have insured the driver had he been properly submitted for approval under the policy. After extensive discovery, briefing, and oral argument, the court rejected the insurer’s attempt to shift responsibility for the $750,000 in coverage it was legally required to provide for permissive drivers under Ohio law, granting summary judgment in favor of the insured and preserving $750,000 in liability exposure.

graphic with Maria Granaudo photo text announces she has joined the firm as a shareholder in the Health Care Dept.

News

Maria R. Granaudo Joins Marshall Dennehey’s Wilmington Office As a Shareholder in the Health Care Department

Thought Leadership

PA Middle District Dismisses Claims Against School District and its Superintendent, Principal, Special Education Director, and Classroom Teacher

A five-year-old special education student was enrolled in the Wyoming Valley West School District and attended the State Street Elementary School during the 2024-2025 school year. The student refused to clean up classroom toys at dismissal. When his teacher allegedly grabbed him by the wrist to walk him back to his seat, the student dropped to the floor and began crying. The teacher then allegedly grabbed the student by the ankle and dragged him across the floor. Following an investigation, criminal charges were not advanced by the county DA, and the school permitted the teacher to return to the classroom. The student’s parents sued, lodging thirteen legal counts under both state and federal law, which sought monetary damages from the teacher, the school district, the superintendent, the principal, and the director of special education. The plaintiff’s 42 USC 1983 claims were dismissed as to the school district for failure to allege a policy or custom violation, and the failure to alleged deliberate indifference in the failure-to-train context. As to the superintendent, building principal, and special education director, the Section 1983 claims were also dismissed for failure to allege personal involvement on the part of the individuals. Regarding an equal protection claim asserted against all defendants, the motion to dismiss was also granted for a failure to advance a plausible equal protection claim, holding that “plaintiffs' single-act allegations do not include a factual basis to even infer that the act was motivated by discriminatory animus rather than some other non-discriminatory impulse.” The court further dismissed the plaintiff’s negligence-based claims including negligence against the teacher and district administrators, NIED, and vicarious liability under the Political Subdivision Tort Claims Act (PSTCA). The federal claims under the IDEA, Section 504, and the ADA were also dismissed in various respects. The IDEA claim was dismissed against all defendants with prejudice for failure to exhaust administrative remedies. The Section 504 claims against the individual defendants were also dismissed with prejudice, as districts, not individuals, are the recipients of federal funds under Section 504. However, the Section 504 and ADA claims were dismissed without prejudice as to defendant Wyoming Valley West, and the plaintiff was permitted leave to amend.

News

Christina Gonzales To Speak at the Women of Color Roundtable at DRI’s Diversity and Inclusion Seminar

News

John J. Hare Featured in Pennsylvania & Delaware Super Lawyers Magazine

Event

29th Annual FDLA Florida Liability Claims Conference

Jim and Erica will team up to present, "Supporting the Next Generation: Connecting with Associates." This panel-style presentation will explore communication best practices from the perspective of a senior shareholder and newer associate. The discussion will focus on the communication styles of different generations and effective strategies to avoid communication breakdowns. Topics to be discussed include the hiring process, perceptions of defense work among newer lawyers, work-life balance issues after hiring, and mentoring.

Thought Leadership

Marijuana Legalization and Workplace Risk: What New Jersey Employers Need to Know

While the legalization of recreational marijuana usage poses a risk of increased work-related accidents for younger workers, employers can work to curb this increase by investing in education, effective drug policies, and employee assistance programs.