IN THE MATTER OF W.L.(C-000012-16, ESSEX COUNTY AND STATEWIDE), A-0455-16T4

Defendant W.L., an NSP inmate, engaged in a prolonged hunger strike (began July 2015 after a prior 2012–13 strike) and refused food and fluids; his health deteriorated with severe malnutrition and cardiac/tissue damage.
Department of Corrections sought emergency relief; trial court entered temporary and then preliminary injunctions (Jan. 21 and Mar. 18, 2016) authorizing involuntary medical treatment, IV hydration, and NG feeding, and use of reasonable force to obtain labs if defendant refused.
The trial judge found imminent risk of irreversible organ damage or death and relied on the Department’s duty to protect inmates in custody.
Defendant filed a four-count counterclaim alleging Eighth Amendment, due process, and First Amendment (retaliation/ political protest) violations; the Department moved to dismiss.
On Aug. 15, 2016 the court dismissed the counterclaim with prejudice for failure to state a claim.
The Appellate Division affirmed the injunction orders (finding no abuse of discretion) but reversed the dismissal with prejudice and remanded for a final hearing on permanency of restraints and to allow amendment of the counterclaim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court properly granted preliminary injunction authorizing involuntary feeding/medical treatment	DOC: immediate intervention necessary to prevent irreversible harm or death; DOC has duty to protect inmates	W.L.: asserted right to protest via hunger strike; challenged DOC decisions that precipitated strike and claimed rights violations	Affirmed — trial court did not abuse discretion; Crowe factors supported injunction due to imminent danger and DOC duty to preserve life
Standard of review for preliminary injunction	DOC: not directly disputed; relied on trial court’s factual findings	W.L.: sought relief from injunction (appeal)	Affirmed — appellate review is narrow; abuse-of-discretion standard applies
Whether dismissal of counterclaim for failure to state a claim was proper	DOC: counterclaim insufficiently pleaded; no deliberate indifference or specific harms alleged	W.L.: argued constitutional claims (Eighth, due process, First) based on transfer and retaliation for hunger strike	Reversed in part — dismissal should have been without prejudice; plaintiff given leave to amend counterclaim
Whether interlocutory appeal was proper and further proceedings required	DOC: sought appellate resolution to validate emergency care orders	W.L.: appealed injunctions and dismissal	Appellate court exercised discretion to decide merits but remanded for final hearing on permanency and allowed amended pleading

Crowe v. De Gioia, 90 N.J. 126 (1982) (sets test/factors for preliminary injunctions in New Jersey)
Nat'l Starch & Chem. Corp. v. Parker Chem. Corp., 219 N.J. Super. 158 (App. Div. 1987) (standard of appellate review for preliminary injunction abuse of discretion)
Printing Mart-Morristown v. Sharp Elecs. Corp., 116 N.J. 739 (1989) (motion to dismiss for failure to state a claim: courts should construe pleadings liberally)
Craig v. Suburban Cablevision, Inc., 140 N.J. 623 (1995) (obscure pleadings that state a fundament of a cause should survive pleading-stage dismissal)