[brief] Plaintiffs also appeal the Trial Court's Order denying their motion for leave to amend their Complaint to amend their New Jersey Civil Rights Act ("CRA"), N.J.S.A. 10:6-1, et seq., Count to add a citation to Article IV, Section VII, paragraph 3 of the New Jersey Constitution (New Jersey's Contract Clause) and to add direct constitutional law claims.  Plaintiffs are retired Atlantic City law enforcement officers.  They allege that they are owed accrued deferred compensation in the form of lump sum payments for accumulated sick time when they retired from their employment.  They accrued this deferred compensation benefit over the course of their decades-long careers and based upon the plain terms of several Collective Negotiations Agreements ("CNAs").  Although the most recent Collective Negotiations Agreement expired before their retirements, our Supreme Court has held that contractual benefits continue to exist beyond the expiration date of the contract if there is clear and unambiguous contractual language that the CNA would remain in effect.  *In Matter of County of Atlantic*, 230 N.J. 237, 255-56 (2017).  The expired CNA, in this matter, had clear language that the contract continued in full force.  Plaintiffs [...], [...], and [...] also assert that they were unlawfully denied compensation for performing the duties of a sergeant following their promotions in 2016.  Defendants contend that the Municipal Stabilization & Recovery Act ("MSRA"), *N.J.S.A. 52:27BBBB-1, et. seq.*, permitted them to revoke the deferred compensation that Plaintiffs accrued over the course of their careers.  However, by the plain language of the statute, the Legislature only authorized Defendants to prospectively nullify contractual terms and benefits.  Stated differently, the MSRA permits the State to terminate contractual rights going forward.  It does not allow Defendants to retroactively alter the terms and conditions of Plaintiffs’ employment where this compensation has already been accrued by Plaintiffs.  This concept is critical to both Plaintiffs' contractual and constitutional claims.  The Court should be guided by *Caponegro v. State Operated School District of the City of Newark, Essex County*, 330 N.J. Super. 148, 151 (App. Div. 2000), which is directly on point.  In this case, pursuant to a state statute, the State took over control of the Newark Public School system and terminated the employment of school administrators.  While the *Caponegro* Court found that the State could unilaterally terminate the plaintiffs’ rights to continued employment, the plaintiffs were still entitled to their accrued deferred compensation such as sick days.  330 N.J. Super. at 155.  Plaintiffs also allege that Defendants’ deprivation of their previously vested deferred compensation also violates the CRA.  In their initial Complaint, Plaintiffs pled a CRA Count based upon Defendants' violation of several provisions of the New Jersey Constitution.  Notwithstanding the foregoing, in reaching its conclusion to dismiss Plaintiff's Complaint with prejudice, the Trial Court decided that there was no reason to consider whether the Defendants acted unconstitutionally.  For the foregoing reasons and the arguments set forth at greater length below, this Court should grant Plaintiffs' appeal and remand this matter to the Trial Court.