Rigoberto Mejia v. New Jersey Department of Corrections, 141 A.3d 1209

Background

In July 2013 prisoner Rigoberto Mejia (serving a long mandatory term) threw a bucket of hot water mixed with urine and feces at two corrections officers from his cell; officers were called, used OC spray, cut a tied bedsheet and extracted him.
Mejia was charged with multiple asterisk (most serious) offenses, pled guilty to one bodily-fluid count and not guilty to others; the hearing officer ultimately found him guilty of four infractions arising from the single incident.
The hearing officer imposed maximum administrative segregation on each count and ran most segregation terms consecutively, producing 1,275 days of administrative segregation (plus loss of commutation and other privileges).
Mejia administratively appealed (initially in Spanish); DOC affirmed without specific findings, later re-reviewed after translation and again affirmed; Mejia appealed to the Appellate Division and was represented on appeal by ACLU-NJ.
Mejia raised (1) the excessive/unreasonable sanction (and need for articulation of sanctioning factors), (2) inadequate mental-health screening/services and vulnerability to prolonged isolation, and (3) denial/inadequacy of interpreter access for hearings and mental-health screening.
The court affirmed guilt but reversed and remanded sanctions as arbitrary and unreasonable, finding Mejia had effectively served more segregation than current rules permit and requiring clearer articulation of sanctioning factors by hearing officers.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 1,275 days administrative segregation (consecutive maximums) was lawful	Mejia: sanctions were arbitrary, excessive, and lacked individualized consideration (mental health, history)	DOC: sanctions were within regulatory limits and procedurally proper	Court: sanctions arbitrary/unreasonable; reversed penalties and remanded (guilt affirmed)
Whether hearing officer must consider and articulate sanctioning factors (e.g., mental illness, history)	Mejia: N.J.A.C. 10A:4-9.17 requires consideration of factors; officer failed to apply or articulate them	DOC: relied on discretionary sanctioning and generic affirmance; no record of required articulation	Court: officers must consider/articulate factors; absence of stated factors prevents meaningful review; reversal of sanctions follows
Adequacy of mental-health screening and effect of segregation on a potentially vulnerable inmate	Mejia: screening was cursory; he may be special-needs and harmed by long isolation	DOC: initially said no evidence of mental-health issues; later disclosed screening under D.M. settlement with cursory reviews	Court: record insufficient to resolve adequacy; concerns remain but no evidentiary hearing conducted; did not resolve merits of mental-health claims here
Whether lack of timely translation/interpreter denied due process and affected review	Mejia: appeal and hearings lacked adequate translation; impeded appeal and access to services	DOC: initially failed to translate appeal; later translated and re-reviewed; argues interpreter provision exists and was used at times	Court: DOC's failure to translate timely prejudiced review and delayed relief; interpreter/communication issues remain unresolved and noted as problematic

Key Cases Cited

D.M. v. Terhune, 67 F. Supp. 2d 401 (D.N.J.) (schooling of mental-health screening obligations in DOC following settlement)
Henry v. Rahway State Prison, 81 N.J. 571 (1980) (standard for appellate review of administrative agency decisions)
In re Issuance of Permit by Dep't of Envtl. Prot., 120 N.J. 164 (1990) (agencies performing quasi-judicial functions must set forth basic findings to permit review)
State v. Fuentes, 217 N.J. 57 (2014) (principle against double-counting in sentencing; need for articulated reasons)
State v. Moran, 202 N.J. 311 (2010) (principle of equal treatment and avoiding disparate dispositions)
DeCamp v. N.J. Dep't of Corr., 386 N.J. Super. 631 (App. Div.) (2006) (scope of appellate review of DOC administrative decisions)
State v. Mejia, 141 N.J. 475 (1995) (prior Supreme Court opinion concerning Mejia's criminal sentence)