JOSEPH M. PALLIPURATH VS. NEW JERSEY DEPARTMENT OFCORRECTIONS(NEW JERSEY DEPARTMENT OF CORRECTIONS), A-1671-15T1

Joseph M. Pallipurath, a New Jersey inmate serving life with lengthy parole ineligibility for multiple shootings, requested out-of-state (Georgia and California) legal reference materials to assist in post-conviction and ineffective-assistance claims.
He submitted an inmate request form but did not provide supporting documents explaining the specific materials or how they were relevant.
DOC responded that the requested materials required in-depth out-of-state legal research and that the Education Department lacked access to such materials; it asked Pallipurath to produce supporting documents for a meeting.
Pallipurath administratively appealed and later claimed agency inaction and retaliation; DOC maintained the request could not be fulfilled given the lack of supporting detail and available resources.
The Appellate Division reviewed the agency decision and affirmed, finding Pallipurath failed to show the materials’ relevancy or that the DOC’s decision was arbitrary, capricious, or unreasonable; collateral challenges to library policy were outside the appeal’s scope.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of out-of-state legal materials	Pallipurath: needed materials to effectively litigate post-conviction and IAC claims	DOC: request lacked specificity and supporting documents; Education Dept. lacks access to out-of-state materials	Affirmed — plaintiff failed to show relevance or that DOC acted arbitrarily, capriciously, or unreasonably
Retaliation for prior grievance	Pallipurath: denial was retaliatory for earlier grievance	DOC: denial was based on lack of substantiation and resource limitations, not retaliation	Affirmed — no adequate showing of retaliation in record
Challenge to DOC law library policy, adequacy, and fees	Pallipurath: library policy/facilities inadequate and fees excessive	DOC: not addressed in this appeal; issues beyond scope of decision under review	Not considered — claims are beyond the limited scope of this appeal

Lewis v. Casey, 518 U.S. 343 (prisoners entitled to adequate law libraries/assistance to present nonfrivolous claims)
Bounds v. Smith, 430 U.S. 817 (prison authorities must assist inmates in preparing legal papers)
Monroe v. Beard, 536 F.3d 198 (access to materials must relate to ability to challenge conviction/conditions; requirement of actual injury)
George Harms Constr. Co. v. N.J. Tpk. Auth., 137 N.J. 8 (scope of appellate review of agency decisions)
Johnson v. Dep't of Corr., 375 N.J. Super. 347 (courts defer to agency findings supported by substantial credible evidence)
In re Arenas, 385 N.J. Super. 440 (burden on challenger to show agency action was arbitrary, capricious, or unreasonable)
Belmont Condominium Ass'n, Inc. v. Geibel, 432 N.J. Super. 52 (limits on raising issues beyond the scope of an appeal)