Ford v. Department of Corrections & Graf v. Department of Corrections

Submitted by New Jersey Criminal Lawyer, Jeffrey Hark.

The facts of both of these cases go as follows: in Ford, Plaintiff in this case was an inmate appealing the denial of his claim for reimbursement for lost, damages, or destroyed property. As he moved from pre-trial hearing detention to general population, his belongings were returned from the inventory list, but plaintiff refused to initial a form stating he received all of his belongings. Plaintiff did so because he stated that there was a television that was not returned to him during this inventory return, and thus he made this claim for loss. However, plaintiff did not mention this television when he received his inventory. In fact, he did not make the claim for loss until one week after he received his belongings. The appellate division reasoned that they could not overrule the DOC because they followed the correct, applicable law. The Superior Court of New Jersey denied plaintiff’s claim.

In Graf, This case comes from an appealed denial from the Department of Corrections denying plaintiff’s application to be reclassified and placed in “full minimum status.” Plaintiff was convicted of murder in 1986 and was sentenced to an aggregate term of life imprisonment with thirty-two years of parole ineligibility. When viewing the appeal, the Superior Court reasoned that they did not have the authority to overrule the DOC as they followed the correct, applicable law. The Superior Court of New Jersey denied plaintiff’s claim.

The court in both cases determined their rulings on similar grounds. Both courts reasoned for the appellate division to overrule the Department of Corrections, the ruling needs to be arbitrary and capricious. The court stated in both cases that the Department of Corrections followed the correct legal outline to avoid an arbitrary and capricious ruling. Thus, the court found in both cases that it did not have the authority to overrule the “DOC” because the legal framework was followed. If the court were to overrule the DOC it would not be respecting the division between the executive and judicial branch. Due to this divide, both courts ruled that they did not have the authority to overrule and affirmed the decisions of the Department of Corrections.