Oscar Porter v. New Jersey Department of Corrections

CourtNew Jersey Superior Court Appellate Division
DecidedJuly 15, 2026
DocketA-1089-24
StatusUnpublished

This text of Oscar Porter v. New Jersey Department of Corrections (Oscar Porter 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
Oscar Porter v. New Jersey Department of Corrections, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1089-24

OSCAR PORTER,

Appellant,

v.

NEW JERSEY DEPARTMENT OF CORRECTIONS,

Respondent. __________________________

Submitted May 7, 2026 ‒ Decided July 15, 2026

Before Judges Bishop-Thompson and Puglisi.

On appeal from the New Jersey Department of Corrections.

Oscar Porter, self-represented appellant.

Jennifer Davenport, Attorney General, attorney for respondent (Janet Greenberg Cohen, Assistant Attorney General, of counsel; Christopher C. Josephson, Deputy Attorney General, on the brief).

PER CURIAM Oscar Porter, an inmate at East Jersey State Prison, appeals from a final

agency decision of the Department of Corrections (DOC) imposing discipline

for committing prohibited act *.203, possession or introduction of any

prohibited substance such as drugs, intoxicants, or related paraphernalia not

prescribed by medical or dental staff. Porter contends the decision was arbitrary,

capricious, and unreasonable because the alleged prohibited substance was not

confirmed by the state laboratory; and therefore, the evidence was insufficient

to find him guilty of the infraction. For the reasons which follow, we reverse.

I.

On September 18, 2024, Correctional Police Officers C. Anastasio and M.

Patella ordered Porter to exit his cell and conducted a pat-frisk. During the

search, Officer Anastasio found three packages of rolling paper in Porter's left

pocket. He also observed and retrieved three blue glove fingertip balloons from

Porter's bed: two balloons contained "suspected" tobacco, and the third

contained "suspected" marijuana. The rolling papers and balloons were

photographed and confiscated. The officers then conducted a strip-frisk of

Porter, but no additional contraband was found. After returning to Porter's cell,

the officers found no further contraband. Porter's urinalysis specimen tested

negative for prohibited substances.

A-1089-24 2 That same day, Porter was charged with committing prohibited act *.203.

The following day, he was served with the disciplinary charge.

The initial hearing, scheduled for September 19, 2024, was adjourned to

allow the Special Investigations Division (SID) to complete its investigation.

The following week, an SID investigator received an email from a DOC

employee that the MobileDetect field test conducted on the substance found in

the third ballon tested positive for synthetic cannabinoids. However, no

confirmatory test was performed by a state laboratory.

The hearing was held on October 8, 2025. Porter's request for counsel

substitute was granted. In the single adjudication report covering both days of

the hearings, the written findings by the same Disciplinary Hearing Officer

(DHO) noted Porter declined to present any witnesses or cross-examine adverse

witnesses and instead pleaded guilty to the charge. The counsel substitute

argued the DOC did not send the substance to the state laboratory for

confirmatory testing. Additionally, the counsel substitute highlighted Porter

was attending school and requested leniency.

Based on the SID reports, the DHO upheld the disciplinary charge. The

DHO then imposed the following sanctions upon Porter: 365 days of urine

monitoring, a permanent loss of contact visits, a 120-day loss of commutation

A-1089-24 3 time, a thirty-day loss of telephone privileges, a thirty-day loss of recreation

privileges, a thirty-day loss of access to his email and JPay accounts, a thirty-

day loss of canteen privileges, and 120 days in the Restorative Housing Unit.

Porter filed an administrative appeal challenging the disciplinary finding

of guilt and the imposed sanctions, but the DOC affirmed the decision. Porter

then appealed the final agency decision. We granted the DOC's motion to

remand the matter in order to amplify the record, specifically regarding the

evidence relied upon to find Porter guilty and the reasons for not obtaining a

confirmatory laboratory test. Porter v. N.J. Dep't of Corr., Docket No. A-1089-

24 (App. Div. Aug. 7, 2025).

The DOC conducted a re-hearing on September 3, 2025, during which

Porter was again assisted by counsel substitute. The counsel substitute asserted

the DOC violated Porter's due process. Porter pleaded not guilty and declined

to make a statement, present witnesses, or cross-examine adverse witnesses.

A different DHO upheld the charge and imposed the same sanctions. The

adjudication form included written findings supporting the decision, stating: the

MobileDetect field test identified the substance; the substance was not sent to

the state laboratory for a confirmatory test because it weighed less than six

ounces; the SID investigator provided a professional opinion that the substance

A-1089-24 4 was marijuana; and photographs of the rubber glove finger were included as

evidence.

Porter filed another administrative appeal, asserting a violation of his due

process rights. The DOC issued its second final agency decision upholding the

DHO's findings and all sanctions. It explained the decision was based on

substantial evidence in the record and the sanctions imposed were appropriate

for the infraction. Porter's request for the reduction or suspension of the

sanctions was denied.

II.

Porter contends the DOC's failure to follow the standard procedure—

requiring investigation and evaluation of the substance by a state laboratory for

confirmation as a controlled dangerous substance—warrants reversal of the

guilty finding. He maintains that the finding was not supported by substantial

credible evidence because the DOC did not establish the reliability of the field

test. Porter asserts the DOC's refusal to submit the substance for confirmatory

testing violated departmental policy and denied him his due process right to

present exculpatory evidence.

Our review of a final agency decision is limited. Zimmerman v. Diviney,

477 N.J. Super. 1, 14 (App. Div. 2023). We do not substitute our judgment for

A-1089-24 5 that of the agency and will not disturb the agency's determination unless it is

arbitrary, capricious, or unreasonable, or is not supported by substantial credible

evidence in the record. Allstars Auto Grp., Inc. v. N.J. Motor Vehicle Comm'n,

234 N.J. 150, 157 (2018). In making this determination, we consider in part

"whether the record contains substantial evidence to support the findings on

which the agency based its action." Id. at 157-58 (quoting In re Stallworth, 208

N.J. 182, 194 (2011)). "'Substantial evidence' means 'such evidence as a

reasonable mind might accept as adequate to support a conclusion.'" Figueroa

v. Dep't of Corr., 414 N.J. Super. 186, 192 (App. Div. 2010) (quoting In re Pub.

Serv. Elec. & Gas Co., 35 N.J. 358, 376 (1961)).

However, our review is not "perfunctory[,]" nor is "our function . . .

merely [to] rubberstamp an agency decision." Id. at 191 (first quoting Blackwell

v. Dep't of Corr., 348 N.J. Super. 117, 123 (App.

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Williams v. Dept. of Corrections
749 A.2d 375 (New Jersey Superior Court App Division, 2000)
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In re Stallworth
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189 A.3d 333 (Supreme Court of New Jersey, 2018)

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