STATE OF NEW JERSEY VS. TROOPER MEGAN HABINA (NEW JERSEY DIVISION OF STATE POLICE), A-3401-19

Trooper Megan Habina lost an Alcohol Influence Report (AIR) used in a DWI arrest and, instead of retrieving a copy, substituted an unrelated AIR, altered it to match the arrest, and forged another trooper’s signature without consent.
Habina admitted the substitution and signing but argued no substantive harm occurred because the blood-alcohol content matched and she feared discipline for losing the AIR.
Separately, Habina filed a burglary investigation report that misidentified a suspect (who had no NJ license), supplied an acquaintance’s address while falsely claiming it was obtained from a Division database, and misstated other troopers’ involvement; the inaccuracies allegedly contributed to a complainant’s arrest.
The Division charged Habina with three offenses (conduct discrediting the Division; making false or misleading official reports; culpable inefficiency) related to both incidents.
An ALJ sustained two of the three charges and recommended termination; the Superintendent adopted the ALJ’s decision, terminated Habina, and found her misconduct violated the standards of professionalism and broke the public trust.
On appeal Habina argued the Division failed to prove she knew the applicable policies (no signed acknowledgement) and that the internal‑affairs interview was unfair/biasing; the Appellate Division affirmed.

Issue	Habina's Argument	State/Division's Argument	Held
Whether the Division had to prove Habina acknowledged receipt or clear knowledge of the policies she allegedly violated	Division did not prove she signed or clearly knew policies; lack of written acknowledgement undermines charges	Troopers are bound to uphold law and professionalism; proof of a signed acknowledgement is not required to find falsification and misconduct	Held: No signed acknowledgment required; conduct objectively violated rules and supported charges
Whether the internal‑affairs interview was unfair or biased, undermining the investigation	Interviewing officer’s conduct was bullying/unfair and fatally impaired the investigation and findings	Interview conduct and credibility claims are immaterial where Habina admitted falsifying reports and record inaccuracies	Held: No merit to bias claim; supervisor/interviewer credibility did not negate the substantiated misconduct
Whether termination was an arbitrary or unreasonable penalty	Lack of experience, fear of discipline, and alleged inadequate supervision mitigate culpability and penalty	Misconduct (altering records, forging signature, false suspect ID) broke public trust; disciplinary decisions fall within agency managerial prerogative	Held: Termination was reasonable, supported by the record, and within agency discretion; affirmed

In re Phillips, 117 N.J. 567 (supreme court of N.J. 1990) (officer’s primary duty to enforce and uphold the law)
Russo v. Bd. of Trs., Police & Firemen’s Ret. Sys., 206 N.J. 14 (N.J. 2011) (standard of review for administrative agency actions)
In re Herrmann, 192 N.J. 19 (N.J. 2007) (administrative decisions reviewed unless arbitrary, capricious, or lacking record support)
Mayflower Sec. Co. v. Bureau of Sec., 64 N.J. 85 (N.J. 1973) (agency legal conclusions reviewed de novo)
Moorestown v. Armstrong, 89 N.J. Super. 560 (App. Div. 1965) (principle cited regarding law‑enforcement obligations)