Little Harris v. New Jersey Department of Corrections

CourtNew Jersey Superior Court Appellate Division
DecidedDecember 18, 2025
DocketA-1495-23
StatusUnpublished

This text of Little Harris v. New Jersey Department of Corrections (Little Harris v. New Jersey Department of Corrections) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Little Harris v. New Jersey Department of Corrections, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1495-23

LITTLE HARRIS,

Plaintiff-Appellant,

v.

NEW JERSEY DEPARTMENT OF CORRECTIONS,

Defendant-Respondent. ____________________________

Submitted December 9, 2025 – Decided December 18, 2025

Before Judges Rose and DeAlmeida.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. L-4033-18.

Little Harris, self-represented appellant.

Matthew J. Platkin, Attorney General, attorney for respondent (Sookie Bae-Park, Assistant Attorney General, of counsel; Elizabeth Merrill, Deputy Attorney General, on the brief).

PER CURIAM Plaintiff Little Harris appeals from two Law Division orders: (1) a May

26, 2023 order denying his motion to reopen a matter closed after he was granted

leave to file a late notice of tort claim against defendant Department of

Corrections (DOC); and (2) a September 8, 2023 order denying his motion for

reconsideration of the May 26, 2023 order. We affirm.

I.

Plaintiff is an inmate in the custody of DOC. On June 8, 2018, plaintiff

filed a motion in the Law Division seeking leave to file a late notice of tort claim

against DOC pursuant to N.J.S.A. 59:8-9. Plaintiff's motion papers did not

describe the nature of his alleged claim or the date on which the claim accrued.

However, plaintiff filed an affidavit stating his vision was "damaged by the

incident," he was "kept in isolation" at Northern State Prison (NSP) for a month

thereafter, and subsequently transferred to the mental health unit of South

Woods State Prison (SWSP), where he was unable to access the law library until

December 2017. DOC did not oppose the motion.

On July 6, 2018, the court entered an order granting plaintiff's motion.

With plaintiff's motion resolved, the court administratively closed the matter.

Over the next nearly five years, plaintiff did not file a notice of tort claim

with DOC. Nor did he file a complaint alleging a tort claim against DOC.

A-1495-23 2 On April 25, 2023, plaintiff moved under the closed docket number "to

reopen the case" to "allow [him] to proceed under normal standards."

Presumably, plaintiff sought to reopen the matter to obtain a second order

permitting him to file a late notice of tort claim against DOC concerning the

same alleged claim addressed in his first motion.

In support of his motion, plaintiff filed a certification alleging on an

unspecified date he was assaulted by corrections officers during a medical escort

while housed at NSP. Plaintiff alleged he suffered serious physical injuries

during the assault. According to the certification, after the incident, plaintiff

was transferred to SWSP, but "most of his legal documents, and misc.

paperwork" was not delivered to him with his other property. Although plaintiff

received a blank notice of tort claim form in 2018 from another inmate, he did

not complete it or file it with DOC. In 2022, plaintiff was transferred to New

Jersey State Prison and again lost legal documents during the move. Plaintiff

certified he is visually impaired and relies on others to assist him in performing

most of his daily functions. He argued these circumstances prevented him from

filing a notice of tort claim after issuance of the July 6, 2018 order. DOC did

not oppose the motion.

A-1495-23 3 On May 26, 2023, the court issued an order denying the motion, which it

treated as a request to vacate a judgment pursuant to Rule 4:50-1(f). The court

concluded:

Plaintiff's [m]otion is DENIED: an [o]rder permitting a late notice of tort claim was granted on June 8, 2018 1 but no complaint was timely filed and the two[-]year statute of limitations has long expired; Plaintiff has not demonstrated any of the bas[e]s to vacate the prior dismissal per [Rule] . . . 4:50-1; and the time to file this motion is more than one year ago; See [Rule] . . . 4:50- 2....

On August 14, 2023, plaintiff moved "to reopen the case." In support of

the motion, plaintiff filed the same certification he filed with his April 25, 2023

motion.

On September 8, 2023, the court issued an order denying the motion,

which it considered a request for reconsideration of the May 26, 2023 order.

The court found "[p]laintiff failed to provide an adequate basis to reconsider"

the prior order. This appeal followed.

1 Although the court stated the prior order was issued on June 8, 2018, that is the date on which plaintiff moved for leave to file a late notice of tort claim. The order granting the motion was issued on July 6, 2018. A-1495-23 4 Plaintiff's brief recounts in detail his recollection of an alleged assault by

corrections officers at NSP on a "forgotten month and day at 8:00." The brief

concludes:

The trial court should grant the plaintiff judgment against the DOC, and amount to be determined. Being that plaintiff was injured and beaten without receiving medical care at the hospital [(sic)]. Nor was there a quasi-judicial procedure done. It was left to diminish over time [(sic)].

Records and dates have been lost due to movements from prison to prison. Dates of events, accuracy of events have been lost. Please accept this brief.

Plaintiff's brief contains no legal citations or arguments challenging the orders

he appeals.

II.

The motion court viewed plaintiff's April 25, 2023 motion to reopen the

matter as a request for relief under Rule 4:50-1(f). That rule provides:

[o]n motion, with briefs, and upon such terms as are just, the court may relieve a party or the party’s legal representative from a final judgment or order for the following reasons: . . . (f) any other reason justifying relief from the operation of the judgment or order.

Relief under this provision is available only when "truly exceptional

circumstances are present." Hous. Auth. of Morristown v. Little, 135 N.J. 274,

286 (1994) (quoting Baumann v. Marinaro, 95 N.J. 380, 395 (1984)). "The

A-1495-23 5 movant must demonstrate the circumstances are exceptional and enforcement of

the judgment or order would be unjust, oppressive or inequitable." Johnson v.

Johnson, 320 N.J. Super. 371, 378 (App. Div. 1999).

In addition, when determining whether a party should be relieved from a

judgment or order, courts must balance "the strong interests in the finality of

litigation and judicial economy with the equitable notion that justice should be

done in every case." Jansson v. Fairleigh Dickinson Univ., 198 N.J. Super. 190,

193 (App. Div. 1985). "[J]ustice is the polestar and our procedures must ever

be moulded and applied with that in mind." Id. at 195 (quoting N.J. Highway

Auth. v. Renner, 18 N.J. 485, 495 (1955)).

A motion under Rule 4:50-1(f) must be "made within a reasonable time"

after entry of the judgment. R. 4:50-2. When determining whether a motion has

been made within a reasonable time, the court must consider "the surrounding

circumstances including the length of time that has passed and a due

consideration for competing rights and interests which have come to exist."

Friedman v. Monaco & Brown Corp., 258 N.J. Super. 539, 543 (App. Div. 1992)

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