The claim could be a harbinger of things to come, with three other corrections officers and three jail staff members dead of COVID-19 in New Jersey since the pandemic began.

A COVID-19 outbreak at the Hudson County Correctional Center, where Waddell worked, caused the deaths of two nurses and a commissary employee at the facility at around the time Waddell died, said da Costa.

In addition, another corrections officer at the same facility, Zeb Craig, died from COVID-19 about a month after Waddell, according to da Costa. And two corrections officers working for the state Department of Corrections have died of COVID-19, according to press accounts. It's unclear if legal action has been taken in any of those cases.

Waddell was exposed to, contracted and died from COVID-19 due to the willful, knowing and reckless conduct of Hudson County, and that conduct was carried out with knowledge that he would be exposed to COVID-19, the tort claims notice states.

Hudson County Counsel Donato Battista said he is aware of the notice of claim in the Waddell case, but said it would be premature to comment before he had all the details. Battista said a workers' compensation application has also been filed in the Waddell case.

Any litigation in Waddell's case will need to prove, pursuant to New Jersey's workers' compensation law, that the dead man's employer intentionally put him at risk, a high standard. But case law provides an exception to that rule where a showing can be made of willful and reckless conduct by an employer.

A claimant seeking to sue a public entity in New Jersey must wait six months after filing a tort claims notice.

In addition to Waddell's case, da Costa has filed 15 tort claims notices in connection with residents, a staff member, and relatives of staff members at the New Jersey Veterans Memorial Home at Menlo Park. All told, 62 residents and one staff member at that facility have died of COVID-19.