ROBERT CURRIER VS. NEW JERSEY STATE PAROLE BOARD(NEW JERSEY STATE PAROLE BOARD), A-3519-13T3

Robert Currier was convicted in 1988 of first-degree robbery and third-degree unlawful possession of a weapon; resentenced in 1991 to an extended term of 50 years with a 17-year mandatory minimum.
Currier was paroled in January 2012; shortly thereafter he tested positive for cocaine, valium, and hydrocodone and later was convicted of DUI in Florida. A parole violation warrant issued and he was returned to New Jersey.
At a March 2013 final revocation hearing Currier admitted four of five alleged violations (drug use, failure to report, DUI, alcohol use) but denied failing to participate in a substance-abuse program.
Hearing Officer Shabazz found Currier did not prove program attendance (no sign-in sheets), observed signs of familiarity with recovery vernacular, and concluded by clear and convincing evidence that Currier committed serious and persistent violations; she recommended revocation and a 12-month future eligibility term.
A two-member Parole Board panel adopted the recommendation; the full Board affirmed on appeal. Currier sought judicial review, arguing the Board’s decision was arbitrary and capricious because it failed to consider all evidence (attendance, accident, prescription issues).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board’s revocation was arbitrary, capricious, or failed to consider all evidence	Currier: Board "rubber stamped" hearing officer, ignored evidence of treatment attendance and mitigating circumstances (accident, need for prescriptions)	Parole Board: record contains substantial testimony on attendance; Board considered mitigation and had factual basis for decision	Court: Affirmed — Board decision supported by substantial credible evidence; not arbitrary or capricious

Trantino v. N.J. State Parole Bd., 166 N.J. 113 (establishes standard of review for parole board actions)
SSI Med. Servs., Inc. v. State, Dep't of Human Servs., Div. of Med. Assistance and Health Servs., 146 N.J. 614 (administrative actions must not be arbitrary, capricious or unreasonable)
Newark v. Natural Res. Council Dep't Envtl. Prot., 82 N.J. 530 (courts accord strong presumption of reasonableness to agency expertise)
Warren Hosp. v. N.J. Dep't of Human Servs., Div. of Mental Health Servs., 407 N.J. Super. 598 (appellate review limited; challenger bears burden of proving arbitrariness)