ABDUR-RAHEEM v. KUHN

CourtDistrict Court, D. New Jersey
DecidedSeptember 10, 2025
Docket3:24-cv-09054
StatusUnknown

This text of ABDUR-RAHEEM v. KUHN (ABDUR-RAHEEM v. KUHN) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ABDUR-RAHEEM v. KUHN, (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY SHAMSIDDIN ABDUR-RAHEEM, | Civil Action No. 24-9054 (RK) (TJB) Plaintiff, : ¥. : MEMORANDUM OPINION ! & ORDER VICTORIA L. KUHN, et al., Defendants. :

This matter has been opened to the Court by Plaintiffs filing of a civil action and an application to proceed in forma pauperis “IFP application”). (ECF Nos, 1, 1-3.) At this time, the Court grants Plaintiff’s IFP application (ECF No. 1-3) and directs the Clerk to file the Complaint. Under the Prison Litigation Reform Act, Pub. L, 104-134, §§ 801-810, 110 Stat. 1321-66 to 1321-77 (Apr. 26, 1996) “PLRA”), district courts must review prisoner complaints when the prisoner is proceeding in forma pauperis. See 28 U.S.C. § 1915(e)(2)(B). The PLRA directs district courts to sue sponte dismiss claims that are frivolous or malicious, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. See 28 U.S.C. § 1915(e)(2)(B). Whether a complaint fails to state a claim under § 1915(e)(2)(B)Gi) is governed by the same standard applicable to motions to dismiss under Federal Rule of Civil Procedure 12(b)(6), see Tourscher v. McCullough, 184 F.3d 236, 240 Gd Cir. 1999), which requires the Court to determine whether the complaint contains “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations omitted), At the pleading stage, the Court accepts the facts alleged in the pro se complaint as true, draws all reasonable inferences in the plaintiff’s favor, and asks only whether the complaint, liberally construed, contains facts sufficient to state a plausible claim.

Shorter v. United States, 12 F.4th 366, 374 Gd Cir. 2021) (quoting Perez v. Fenoglio, 792 F.3d 768, 774, 782 (7th Cir. 2015)). Conclusory allegations, however, do not suffice. Iqbal, 556 U.S. at 678. Plaintiff alleges that between January and April 2024, he was expecting mail from at least 20 businesses to whom he had sent mail. (Complaint at § 18.) On April 21, 2024, he wrote an informal grievance about the issue and received a response from the mailroom sergeant Michael Kostbar who informed him that the prison mail room does not accept mail from post office boxes. (d. at § 19.) Plaintiff filed a formal grievance on April 27, 2024, about not receiving mail from “WriteAPrisoner.com,” and Kostbar responded that mail is not accepted from post office boxes, Ud.) Kostbar also responded to Plaintiff's final administrative appeal. (Ud. {| 20.) According to Plaintiff, the new policy of refusing mail from post office boxes is not authorized by existing regulations and inmates have not been informed about it through the inmate handbook. (/d. at 4{ 21-25.) Inmates also do not receive notice that the mail has been returned to the sender. (/d. at § 26.) Plaintiff alleges that Kostbar, who is the mailroom sergeant, is the prison official who returned his mail without notice. Ud. at | 29.) Plaintiff has also sued a number of administrators in connection with the alleged mail policy. He alleges that Victoria L. Kuhn, Commissioner of the NIDOC, Willie Bonds, Assistant Deputy Commissioner of the NJDOC, Erin Nardelli, Assistant Commissioner of the NJDOC, Donna Gies, Assistant Commissioner of the NJDOC, and Melinda Haley, Assistant Commissioner of the NJDOC are responsible for “implementing and enforcing” NJDOC policies. (See Complaint at fj 4-8.) Plaintiff further alleges that Kuhn, Bonds, Nardelli, Gies, and Haley are responsible for “enacting, authorizing, implementing and enforcing this new

unconstitutional policy prohibiting inmates from receiving mail from P.O. boxes without providing them or the sender any due process notice of and for these occurrences.” (d. at 30.) According to the Complaint, Bruce Davis, Administrator of NJSP, Amy Emrich, Assistant Administrator of NJSP, and Derrick Bodtmann, Assistant Superintendent of the NJSP

are also allegedly responsible for enforcing the mail policy at NISP. (éd. at 10-12.) Plaintiff further contends that due to their roles within NJSP, Davis, Emrich, and Bodtmann were aware that Kostbar was rejecting his incoming mail sent from post office boxes. (Jd. at 29.) Plaintiff raises claims under 42 U.S.C. § 1983 and seeks damages and injunctive relief.! (id. at 4 32-41.) To state a claim under § 1983, a plaintiff must allege the violation of a right secured by the Constitution or laws of the United States and that the alleged deprivation was committed or caused by a person acting under color of state law. See Harvey v. Plains Twp. Police Dep t, 635 F.3d 606, 609 (3d Cir. 2011); see also West y, Atkins, 487 US. 42, 48 (1988), The Court construes Plaintiff to assert a First Amendment and Fourteenth Amendment procedural due process claim against Kostbar, the mailroom sergeant who allegedly followed the mail policy by failing to deliver his mail from post office boxes and returning that mail without notifying him. “[S]tate prisoners, by virtue of their incarceration, do not forfeit their First Amendment right to use of the mails.” Jones v. Brown, 461 F.3d 353, 358 Gd Cir. 2006) (internal quotation marks and citation omitted).? The Supreme Court has also recognized a liberty interest in communicating by mail. See Procunier v. Martinez, 416 U.S, 396, 418 (1976);

! The Court construes Plaintiff to sue Defendants in their personal capacities for damages and in their official capacities for injunctive relief. 2 Under Turner v. Safley, 482 U.S. 78, 89 (1987), however, a prison regulation that impinges on inmates constitutional rights is valid if it is reasonably related to legitimate penological interests. Here, the Court is unable to determine at the screening stage if the purported policy barring incoming mail from post office boxes without notice is reasonably related to legitimate penologicai interests.

see also Vogt v, Wetzel, 8 F.4th 182, 187 (3d Cir. 2021) (recognizing that prisoners “have a liberty interest in corresponding by mail” and finding that notification was required when rejecting prisoner’s letter). At this early stage, the Court proceeds the First Amendment and Fourteenth Amendment due process claim against Kostbar for allegedly enforcing the mail policy and rejecting Plaintiff’s mail sent from post office boxes without notice? Plaintiff’s has also sued a number of supervisory officials. Notably, government entities and supervisors cannot be held responsible under § 1983 for the acts of their employees under the traditional principles of vicarious liability. Igbal, 556 U.S. at 676, Natale v. Camden Cty. Corr, Facility, 318 F.3d 575, 583 (3d Cir. 2003) (citing Monell v. New York City Dept. of Soc.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Santiago v. Warminster Township
629 F.3d 121 (Third Circuit, 2010)
Harvey v. Plains Township Police Department
635 F.3d 606 (Third Circuit, 2011)
John Colwell v. Robert Bannister
763 F.3d 1060 (Ninth Circuit, 2014)
Miguel Perez v. James Fenoglio
792 F.3d 768 (Seventh Circuit, 2015)
C.H. v. Oliva
226 F.3d 198 (Third Circuit, 2000)
Jones v. Brown
461 F.3d 353 (Third Circuit, 2006)
Brooks v. Beard
167 F. App'x 923 (Third Circuit, 2006)
Baraka v. McGreevey
481 F.3d 187 (Third Circuit, 2007)
Donald Parkell v. Carl Danberg
833 F.3d 313 (Third Circuit, 2016)
Steven Vogt v. John Wetzel
8 F.4th 182 (Third Circuit, 2021)
Christopher Shorter v. United States
12 F.4th 366 (Third Circuit, 2021)

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Bluebook (online)
ABDUR-RAHEEM v. KUHN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abdur-raheem-v-kuhn-njd-2025.