STATE OF NEW JERSEY VS. T.R.G.(13-01-0003, CAMDEN COUNTY AND STATEWIDE)(RECORD IMPOUNDED), A-5308-14T2

Inmate Thomas Liddell was found in the ADTC law library on June 17, 2015 despite not being on the law library schedule.
Senior Corrections Officer R. Bradley ordered Liddell to leave; Liddell disputed receiving a direct order but complied after Sgt. Lewandowski arrived and ordered him to return to his unit.
Liddell was charged with violating facility rules: .256 (refusing to obey an order) and .402 (being in an unauthorized area); a disciplinary hearing followed and he pled not guilty.
Hearing Officer Nolley credited Bradley’s testimony (and one inmate witness) that Bradley twice told Liddell to leave and that Liddell acknowledged but refused, then contacted the sergeant who ordered him out.
Nolley found Liddell guilty and imposed sanctions; an associate administrator upheld the findings but reduced some sanctions and suspended most administrative segregation days.
Liddell appealed to the Appellate Division, arguing lack of a direct order, immediate compliance with the sergeant, that use of the library was permissible (ex post facto argument), and violations of due process and confrontation rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hearing denied minimal due process (notice, confrontation, witnesses)	Liddell asserts his due process and confrontation rights were violated.	DOC contends Liddell received required process: notice, ability to call witnesses, and to confront Bradley.	Court held due process rights were satisfied; no violation.
Sufficiency of evidence for refusal to obey and unauthorized area	Liddell says Bradley did not give a direct order and he complied when ordered by sergeant.	DOC relies on Bradley’s and a witness’s testimony that Bradley twice ordered Liddell to leave and Liddell refused.	Court held there was substantial credible evidence to support guilt.
Whether presence in library was permitted / ex post facto claim	Liddell contends he believed library access was authorized and that charges are effectively ex post facto.	DOC asserts inmate was not on schedule and staff orders must be followed regardless of inmate belief.	Court rejected ex post facto claim and found inmate’s belief irrelevant; DOC rules govern.
Deference to prison administration and sanctions review	Liddell argues sanctions and procedures were improper.	DOC emphasizes need for deference to maintain security and order in prisons.	Court affirmed sanctions (with administrative modification already applied) and deferred to prison administrators.

Stallworth v. New Jersey Dep't of Corr., 208 N.J. 182 (discussing limited scope of appellate review of agency decisions)
Henry v. Rahway State Prison, 81 N.J. 571 (prison disciplinary proceedings and review standards)
Ramirez v. Dep't of Corr., 382 N.J. Super. 18 (standard of review for corrections decisions)
In re Arenas, 385 N.J. Super. 440 (burden on challenger to show agency action arbitrary or capricious)
Avant v. Clifford, 67 N.J. 496 (limited due process protections in prison disciplinary hearings)
McDonald v. Pinchak, 139 N.J. 188 (prisoner rights in disciplinary proceedings)
In re Pub. Serv. Elec. & Gas Co., 35 N.J. 358 (definition of substantial evidence)
Jones v. Dep't of Corr., 359 N.J. Super. 70 (inmate rights to confrontation and witness access in disciplinary hearings)
Jenkins v. Fauver, 108 N.J. 239 (deference to DOC rulemaking to maintain security)
Russo v. N.J. Dep't of Corr., 324 N.J. Super. 576 (courts’ deference to prison administrators to manage volatile environment)