SHAZAM MEIGHOO VS. NEW JERSEY DEPARTMENT OF CORRECTIONS (NEW JERSEY DEPARTMENT OF CORRECTIONS), A-5072-18T3

In June 2019, inmate Shazam Meighoo (serving an 18-year sentence) was housed at Northern State Prison when a random cell search uncovered a razor blade melted onto a pen and wrapped in cloth inside a plastic bin labeled with his name.
Meighoo was charged under prohibited act *.202 (possession/introduction of a weapon) and placed in prehearing detention.
He denied ownership, claimed a cellmate made such items, and requested a polygraph, fingerprint analysis of the weapon, and video footage of his cell during the relevant period; all requests were denied by prison officials.
At the disciplinary hearing Meighoo declined to call witnesses or cross-examine staff; the DHO reviewed staff reports, testimony, and the bin, found him guilty, and imposed sanctions (later partially reduced by the administrator).
Meighoo appealed claiming due process violations (burden shifting; denial of requested evidence). The Appellate Division affirmed the NJDOC decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient evidence and whether burden was shifted	Meighoo: DHO shifted burden to him and failed to state NJDOC met its burden	NJDOC: Staff reports and discovery of weapon in Meighoo's labeled bin provide substantial evidence; DHO followed regs and noted NJDOC had burden	Affirmed. Substantial evidence supports guilt; DHO identified evidence and did not improperly shift burden
Denial of polygraph request	Meighoo: Polygraph needed to resolve credibility and show weapon was planted	NJDOC: Polygraph discretionary; regs do not grant inmates an automatic right and denial is permissible absent serious credibility issue	Denial upheld. No serious credibility issue; denial not arbitrary or fundamentally unfair
Denial of fingerprint analysis	Meighoo: Fingerprint testing could prove non-ownership	NJDOC: No right to testing; negative fingerprints would not conclusively show non-ownership given location of contraband	Denial upheld. Testing would not have dispositively resolved ownership; fairness not compromised
Denial of requested video footage	Meighoo: Video could show weapon was planted while he attended services	NJDOC: Request speculative; no evidence presented to show planting occurred during requested time	Denial upheld. Request denial not arbitrary and did not affect fundamental fairness

George Harms Constr. Co. v. N.J. Turnpike Auth., 137 N.J. 8 (discusses severely limited scope of appellate review of agency decisions)
Gloucester Cty. Welfare Bd. v. N.J. Civil Serv. Comm'n, 93 N.J. 384 (appellate intervention in agency actions is limited)
Blanchard v. N.J. Dep't of Corrs., 461 N.J. Super. 231 (use substantial evidence standard in prisoner disciplinary appeals)
Henry v. Rahway State Prison, 81 N.J. 571 (standards for reviewing prison disciplinary findings)
McDonald v. Pinchak, 139 N.J. 188 (departmental regulations implement inmates procedural due process protections)
Jacobs v. Stephens, 139 N.J. 212 (same — obligations to follow departmental disciplinary regs)
Ramirez v. Dept. of Corrs., 382 N.J. Super. 18 (inmate has no absolute right to a polygraph; requests are discretionary)
Johnson v. N.J. Dept. of Corrs., 298 N.J. Super. 79 (polygraphs are not required in every case)