MILDALIA MADLINGER VS. NEW JERSEY TRANSIT CORPORATION (L-4844-14, ESSEX COUNTY AND STATEWIDE), A-2310-16T2

Appellant Jammie Skazenski, an incarcerated person at Northern State Prison, was accused of using a prohibited substance after a positive urine test and charged with prohibited act *.204.
DOC investigators acted on an anonymous tip that inmates in Skazenski's unit were using drugs and required urine testing to ensure prison safety.
Skazenski claimed he provided an initial negative sample on December 1, 2015, and that a second sample on December 2 was taken without factual basis, was mishandled, and may have been misidentified (report body named a different inmate; timing discrepancy).
DOC's record showed only one sample collected on December 2, 2015, which tested positive; continuity-of-evidence forms and ID numbers matched the sample collected in Skazenski’s presence.
At the disciplinary hearing Skazenski declined to call witnesses or cross-examine adverse witnesses, offered a written statement, and the hearing officer accepted DOC’s explanation that a name in the report body was a clerical/template error.
The hearing officer found Skazenski guilty and imposed sanctions; DOC denied his administrative appeal, and the Appellate Division affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DOC had factual basis to require/obtain a second urine sample	Skazenski: no factual basis for additional testing under N.J.A.C. 10A:3-5.10(b)(8)	DOC: anonymous tip about unit drug use provided sufficient basis for testing	Held: DOC had sufficient basis; testing lawful and supported by record
Whether Skazenski was denied due process / fair hearing by lack of access to evidence and alleged mislabeling	Skazenski: report misidentified another inmate and timing/labeling errors denied him a fair hearing	DOC: clerical/template error explained; continuity forms, ID numbers, and sealing in his presence establish chain and accuracy	Held: procedural due process protections met; substantial credible evidence supported guilt and sanctions

Jackson v. Department of Corrections, 335 N.J. Super. 227 (App. Div. 2000) (prison safety justifies drug testing of inmates)
Hamilton v. New Jersey Department of Corrections, 366 N.J. Super. 284 (App. Div. 2004) (urine testing permissible to ensure prison security)
Avant v. Clifford, 67 N.J. 496 (1975) (prison disciplinary proceedings afford limited due process protections)
In re Herrmann, 192 N.J. 19 (2007) (scope of appellate review of agency decisions)
Henry v. Rahway State Prison, 81 N.J. 571 (1980) (agency decisions upheld unless arbitrary, capricious, unreasonable, or unsupported by substantial evidence)
In re Taylor, 158 N.J. 644 (1999) (appellate review limited to whether findings are supported by substantial evidence)
In re Hackensack Water Co., 41 N.J. Super. 408 (App. Div. 1956) (definition of substantial evidence)