Tianle Li v. New Jersey Department of Corrections

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 6, 2026
DocketA-2514-24
StatusUnpublished

This text of Tianle Li v. New Jersey Department of Corrections (Tianle Li 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.

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Tianle Li 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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2514-24

TIANLE LI,

Appellant,

v.

NEW JERSEY DEPARTMENT OF CORRECTIONS,

Respondent. __________________________

Submitted December 10, 2025 – Decided January 6, 2026

Before Judges Mayer and Gummer.

On appeal from the New Jersey Department of Corrections.

Tianle Li, self-represented appellant.

Matthew J. Platkin, Attorney General, attorney for respondent (Janet Greenberg Cohen, Assistant Attorney General, of counsel; Leo R. Boerstoel, Deputy Attorney General, on the brief).

PER CURIAM Tianle Li, an inmate at a correctional facility, appeals from a March 26,

2025 final decision of the New Jersey Department of Corrections (DOC). The

DOC found Li guilty of prohibited act *.012 for "throwing bodily fluid at any

person or otherwise" and imposed sanctions for that violation.1 Li contends the

record lacked substantial evidence she had committed the prohibited act and that

the DOC erroneously based its decision on a prior disciplinary infraction. We

disagree and affirm.

On March 20, 2025, another inmate informed an officer that Li had spit

on her. The officer spoke to Li, who asserted the other inmate had spit on her.

After another officer reviewed video evidence of the inmates' encounter, Li was

charged with *.012, "throwing bodily fluid at any person or otherwise," a

prohibited act under N.J.A.C. 10A:4-4.1(a)(1)(x). Li was served with notice of

the disciplinary charge. She pleaded not guilty and did not request counsel

substitute.

A disciplinary hearing officer conducted a hearing. The hearing officer

considered officers' reports and video evidence of the incident. Li declined the

1 "Prohibited acts preceded by an asterisk (*) are considered the most serious and result in the most severe sanctions." N.J.A.C. 10A:4-4.1(a). A-2514-24 2 opportunity to call witnesses in her defense. She pleaded not guilty and stated:

"I'm totally innocent. She spit on me before. I did not spit on her ."

The hearing officer found Li guilty of prohibited act *.012. Referencing

the officers' reports and the video as evidence of Li's guilt, the hearing officer

concluded Li was seen on the video spitting on the other inmate. The hearing

officer imposed ninety days in the restorative housing unit (RHU), ninety days'

loss of commutation time, and thirty days' loss of phone, JPay, email, canteen,

and media-download privileges. 2 Under the "[r]eason(s) for sanction(s)" section

of the adjudication report, the hearing officer referenced, among other things,

Li's prior disciplinary history, specifically her "[l]ast charge," which the hearing

officer described as prohibited act *.256 on March 4, 2025. Prohibited act *.256

is based on a violation of N.J.A.C. 10A:4-4.1(a)(2)(xvii), "refusing to obey an

order of any staff member."

2 Pursuant to N.J.A.C. 10A:5-9.2, an RHU is "a structured, controlled environment where inmate behavior shall be closely monitored and documented by a team of custody and civilian staff." Commutation credit is awarded to inmates, pursuant to N.J.S.A. 30:4-140, "for continuous orderly deportment." JPay is "a service that allows individuals to transfer money to inmates." Libertarians for Transparent Gov’t v. Cumberland Cnty., 465 N.J. Super. 11, 14 (App. Div. 2020). A-2514-24 3 Li administratively appealed to the DOC the hearing officer's decision on

the *.012 charge. The DOC reduced the RHU time to sixty days and upheld the

finding of guilt and the other sanctions.

On appeal to this court, Li argues the evidence did not support the hearing

officer's conclusion she had spat on the other inmate, thereby committing

prohibited act *.012. Li further argues the *.012 violation should be dismissed

because the hearing officer erred in basing the disposition of the *.012 charge

on the prior *.256 charge. We disagree.

"Our review of an administrative agency's final determination is limited."

Columbia Fruit Farms, Inc. v. Dep't of Cmty. Affs., 470 N.J. Super. 25, 36 (App.

Div. 2021). In reviewing an agency decision, we determine: "1) whether the

decision is consistent with the agency's governing law and policy; 2) whether

the decision is supported by substantial evidence in the record; and 3) whether,

in applying the law to the facts, the agency reached a decision that could be

viewed as reasonable." Id. at 37. "We will disturb an agency's adjudicatory

decision only upon a finding that the decision is 'arbitrary, capricious or

unreasonable,' or is unsupported 'by substantial credible evidence in the record

as a whole.'" Blanchard v. N.J. Dep't of Corr., 461 N.J. Super. 231, 237-38

(App. Div. 2019) (quoting Henry v. Rahway State Prison, 81 N.J. 571, 579-80

A-2514-24 4 (1980)); see also M.R. v. N.J. Dep't of Corr., 261 N.J. 322, 337 (2025). The

challenger of the agency decision bears the burden of proving the decision was

"arbitrary, unreasonable or capricious." In re M.M., 463 N.J. Super. 128, 136

(App. Div. 2020) (quoting McGowan v. N.J. State Parole Bd., 347 N.J. Super.

544, 563 (App. Div. 2002)). We are not bound by an agency's statutory

interpretation or other legal determinations and review those de novo. Conley

v. N.J. Dep't of Corr., 452 N.J. Super. 605, 613 (App. Div. 2018).

In an appeal from a final DOC decision in a prisoner disciplinary matter,

we consider whether the record contains substantial evidence to support the

decision the inmate committed the prohibited act. Blanchard, 461 N.J. Super. at

237-38; see also N.J.A.C. 10A:4-9.15(a) ("finding of guilt at a disciplinary

hearing shall be based upon substantial evidence"). "Substantial evidence has

been defined alternatively as 'such evidence as a reasonable mind might accept

as adequate to support a conclusion,' and 'evidence furnishing a reasonable basis

for the agency's action.'" Blanchard, 461 N.J. Super. at 238 (quoting Figueroa

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

Having reviewed the record, we are satisfied it contains substantial

credible evidence that supports finding Li guilty of prohibited act *.012. The

A-2514-24 5 video evidence and the officers' reports supported the determination that Li had

spat on another inmate.

Li faults the hearing officer for basing the disposition of the *.012 charge

on the prior *.256 charge, contending the charges were unrelated and fabricated

and that the *.012 charge was made in retaliation to her grievances about the

*.256 charge. Nothing in the record indicates the hearing officer who found Li

guilty of the *.012 charge had based that finding on the *.256 charge. To the

contrary, the hearing officer stated she had relied on the video evidence and the

officers' reports in determining Li's guilt.

An inmate is generally "entitled to individualized reasons for the specific

sanctions imposed." Malacow v. N.J. Dep't of Corr., 457 N.J. Super. 87, 97

(App. Div. 2018). Under N.J.A.C. 10A:4-9.17(a), a disciplinary hearing officer

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Related

Figueroa v. DEPT. OF CORRECTIONS
997 A.2d 1088 (New Jersey Superior Court App Division, 2010)
Henry v. Rahway State Prison
410 A.2d 686 (Supreme Court of New Jersey, 1980)
McGowan v. NJ State Parole Bd.
790 A.2d 974 (New Jersey Superior Court App Division, 2002)
Rigoberto Mejia v. New Jersey Department of Corrections
141 A.3d 1209 (New Jersey Superior Court App Division, 2016)

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