Kaseem Ali-X v. New Jersey Department of Corrections
A-3546-22
N.J. Super. Ct. App. Div.Jun 2, 2025Background
- Kaseem Ali-X, an inmate, purchased refried beans from an outside vendor through the prison's "Incentive Food Package" program, believing the beans were kosher.
- Upon receipt, Ali-X discovered the beans contained lard and were not kosher as expected.
- The vendor offered a refund if the beans were returned, but the correctional facility refused shipment, citing a policy against shipping food from the prison.
- Ali-X filed multiple grievances regarding the inability to return the beans and receive a refund, which were denied by the New Jersey Department of Corrections (DOC) and were not timely appealed to court.
- Over three years later, Ali-X filed a property claim with the DOC seeking refund and postage reimbursement, which was denied as untimely; he then appealed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of Property Claim | The DOC's refusal deprived Ali-X of due process and restitution | Claim was filed years after the incident | Claim was untimely under regulations—affirmed denial |
| Due Process Violation | Department abused authority, recklessly disregarding rights | Enforced established prison rules/notice given | No due process violation—actions not arbitrary |
| Notice of Prison Policy | Not given proper notice of rule prohibiting returns | Rules are in Inmate Handbook and were followed | Prison followed rules; lack of notice unsupported |
| Punitive Damages | Claimed willful misconduct by DOC employees warrants damages | Claim not previously raised; outside scope of review | Claim not considered; not properly preserved or timely |
Key Cases Cited
- In re Stallworth, 208 N.J. 182 (2011) (sets standard for appellate review of administrative agency decisions)
- In re Carroll, 339 N.J. Super. 429 (App. Div. 2001) (presumption of reasonableness attaches to agency decisions)
- Henry v. Rahway State Prison, 81 N.J. 571 (1980) (standard for overturning administrative agency decisions: arbitrary, capricious, or unreasonable)
