MATCHAPONIX ESTATES, INC. VS. FIRST MERCURYÂ INSURANCE COMPANY (L-4399-15, MIDDLESEX COUNTY AND STATEWIDE), A-4784-15T4

Background

Appellant U'Bay Lumumba, an inmate serving life with parole ineligibility, sought free photocopies of legal materials under N.J.A.C. 10A:6-2.6, claiming indigent status because administrative segregation prevented him from earning wages.
DOC denied indigent status under N.J.A.C. 10A:1-2.2, determining his inability to work resulted from disciplinary placement in administrative segregation (an avoidable circumstance) rather than "prolonged illness or any other uncontrollable circumstance." DOC instead advanced loans to his inmate account to cover copy costs.
Lumumba exhausted internal remedies: inmate inquiry, grievance, NJSP administrative appeal, and an appeal to the DOC Commissioner, which was denied by final agency decision dated January 20, 2015.
The DOC relied on regulations permitting limited work opportunities for inmates in administrative segregation subject to security, resources, facilities, and budget constraints (N.J.A.C. 10A:5-3.16), and the definition of indigent in N.J.A.C. 10A:1-2.2.
Lumumba argued DOC violated N.J.S.A. 30:4-92, N.J.A.C. 10A:5-3.16, and the NJSP Inmate Handbook by denying work opportunities and thereby improperly denying indigent status.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lumumba qualified as an "indigent inmate" entitled to free legal photocopies under N.J.A.C. 10A:1-2.2 and 10A:6-2.6	Lumumba: administrative segregation prevented him from earning wages and was not an uncontrollable circumstance caused by him; DOC's restrictions violated statutory/regulatory duties to provide work	DOC: Lumumba's segregation resulted from his disciplinary misconduct; inability to work was therefore not an uncontrollable circumstance and DOC properly denied indigent status	Affirmed: DOC reasonably found Lumumba not indigent because segregation was disciplinary and avoidable, so he must repay loans for copies
Whether DOC violated N.J.S.A. 30:4-92 or other rules by restricting work opportunities in administrative segregation	Lumumba: statute/regulations guarantee employment; denial unlawfully prevented him from earning wages and becoming indigent	DOC: N.J.S.A. 30:4-92 does not guarantee a specific job; regulations allow discretion to offer work in segregation subject to security/resources	Affirmed: DOC acted within discretion; work in segregation is discretionary and constrained by security/resources
Standard of review and whether agency decision was arbitrary, capricious, or unsupported	Lumumba: agency erred in applying the indigency regulation and misapplied law	DOC: decision supported by record and reasonable interpretation of regulations	Affirmed: court defers to agency interpretation within its authority and finds decision supported by substantial evidence
Whether disciplinary sanctions impermissibly impede appellate access	Lumumba: denial of free copies hindered ability to pursue appeals	DOC: denial based on regulation; not intended to block appellate review	Court: cautioned agencies to avoid sanctions that unreasonably impede access to appellate review; no reversal here

Key Cases Cited

Figueroa v. N.J. Dep't of Corr., 414 N.J. Super. 186 (App. Div.) (standard for reviewing DOC administrative decisions)
In re Taylor, 158 N.J. 644 (1999) (framework for judicial review of administrative action)
Henry v. Rahway State Prison, 81 N.J. 571 (1980) (agency decisions disturbed only if arbitrary, capricious, or unsupported)
Lorusso v. Pinchak, 305 N.J. Super. 117 (App. Div.) (no protected liberty interest in a particular prison job)
Jenkins v. Fauver, 108 N.J. 239 (1987) (broad deference to prison administration)
Russo v. N.J. Dep't of Corr., 324 N.J. Super. 576 (App. Div.) (deference and flexibility owed to prison administrators)
McDonald v. Pinchak, 139 N.J. 188 (1995) (courts must ensure disciplinary sanctions do not undermine appellate access)