U'bay Lumumba v. New Jersey State Parole Board

CourtNew Jersey Superior Court Appellate Division
DecidedMay 21, 2024
DocketA-1997-22
StatusUnpublished

This text of U'bay Lumumba v. New Jersey State Parole Board (U'bay Lumumba v. New Jersey State Parole Board) 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
U'bay Lumumba v. New Jersey State Parole Board, (N.J. Ct. App. 2024).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1997-22

U'BAY LUMUMBA,

Appellant,

v.

NEW JERSEY STATE PAROLE BOARD,

Respondent. _________________________

Submitted May 7, 2024 – Decided May 21, 2024

Before Judges Mayer and Whipple.

On appeal from the New Jersey State Parole Board.

U'Bay Lumumba, appellant pro se.

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

PER CURIAM U'Bay Lumumba, an inmate at East Jersey State Prison, appeals from the

January 25, 2023 final agency decision of the State Parole Board (Board)

denying his parole and imposing a thirty-six-month future eligibility term (FET).

We affirm.

Lumumba is serving an aggregate sentence of life imprisonment with a

mandatory-minimum term of thirty-five years for murder, robbery, aggravated

assault, possession of a weapon for an unlawful purpose, and unlawful

possession of a weapon. Lumumba became eligible for parole for the second

time on May 30, 2022. On March 11, 2022, after serving approximately thirty-

six years of his sentence, Lumumba received an initial hearing, after which a

hearing officer referred the matter to a Board panel for a subsequent hearing. In

April 2022, a two-member panel conducted a hearing and referred Lumumba for

a full Board hearing under N.J.A.C. 10A:71-3.18(c). In July 2022, the full Board

conducted a parole release hearing, denied parole, and referred the matter to the

full Board for the establishment of an FET that exceeded the administrative

guidelines.

The full Board based its decision on numerous factors, including: the facts

and circumstances of the offense; Lumumba's extensive and repetitive prior

record; the increasingly more serious nature of his criminal record; the fact he

A-1997-22 2 was sentenced for multiple offenses; his commission of a new offense while on

probation, though his status was not formally revoked; prior incarceration and

probation had failed to deter his criminal behavior; and his numerous, persistent

institutional disciplinary infractions which were serious in nature and which

resulted in loss of commutation time, confinement in detention, and

Administrative Segregation. The Board also considered Lumumba's insufficient

problem resolution, his lack of insight into his criminal behavior, and his

minimization of his own conduct—as demonstrated by his panel interview, pre-

parole report, documentation in the case file, and confidential material. Finally,

the Board took into account his commission of his current offenses while on bail

and the results of an objective risk assessment that indicated a "moderate" risk

of recidivism.

As mitigating factors, the Board acknowledged Lumumba was infraction-

free since the previous panel hearing; he participated in institutional programs

specific to his behavior; institutional reports reflected a favorable institutional

adjustment; he attempted to enroll in programs, though he was not admitted; and

his commutation time had been restored. On October 12, 2022, the full Board

convened and established a thirty-six-month FET, basing its decision on the

same factors that it relied upon in denying Lumumba parole.

A-1997-22 3 Lumumba administratively appealed the full Board's decision, and the

Board affirmed the denial of parole and imposition of a thirty-six-month FET

on January 25, 2023. The Board rejected Lumumba's arguments the panel did

not consider material facts and that the panel had failed to document that a

preponderance of the evidence indicated a substantial likelihood he would

commit a new crime if released on parole.

Rather, the Board found that it properly considered his entire record—

including his juvenile record—and contrary to his claim, it was not limited to

assessing only "new" material at each subsequent parole consideration. The

Board likewise rejected Lumumba's argument that it should have considered the

COVID-19 crisis and his positive COVID test as mitigating factors . The Board

noted it was cognizant of the impact of COVID-19 in New Jersey prisons, but

that it was not a sufficient basis for granting parole.

Lumumba also argued that the Board should have rescinded its decision

denying parole because it relied upon a mental-health evaluation conducted by

a psychologist who had allegedly been "fired" and "criminally charged" two

months prior to the Board's denial of his parole. In light of the allegations

against the psychologist, however, the Board had ordered a new psychological

evaluation of Lumumba be conducted by a different evaluator prior to

A-1997-22 4 establishing the FET. Thus, on October 4, 2022, Lumumba underwent another

evaluation, which the Board considered the following week when it convened to

establish the FET. During the administrative appeal, the Board reviewed both

mental-health evaluations in Lumumba's case and found that "appropriate

decisions were made by the Board in its July 21, 2022 decision to deny

[Lumumba] parole and the Board's October 12, 2022 determination to establish

a thirty-six . . . month future eligibility term."

This appeal followed on March 6, 2023.

On appeal, Lumumba argues the Board unreasonably denied his parole

request and imposed a thirty-sixty-month FET and that the Board should have

been limited to only considering new information obtained since his first parole

hearing. We disagree.

Our review of final decisions of the Board is limited. Malacow v. N.J.

Dep't of Corr., 457 N.J. Super. 87, 93 (App. Div. 2018). The Board's decisions,

like those of other administrative agencies, will not be reversed unless they are

"arbitrary, capricious[,] or unreasonable or [are] not supported by substantial

credible evidence in the record as a whole." Henry v. Rahway State Prison, 81

N.J. 571, 579-80 (1980). This limited review of parole determinations accords

agency action a presumption of validity and reasonableness. In re Vey, 272 N.J.

A-1997-22 5 Super. 199, 205 (App. Div. 1993). The burden is on the challenging party to

show the Board's actions were unreasonable. Bowden v. Bayside State Prison,

268 N.J. Super. 301, 304-05 (App. Div. 1993).

Pursuant to N.J.S.A. 30:4-123.53(a), the Board should generally grant

parole requests for release on an inmate's parole date, unless it can be shown by

a preponderance of the evidence that the inmate failed to cooperate in their own

rehabilitation or there is a "reasonable expectation that the inmate will violate

conditions of parole." In determining Lumumba should not be released on

parole, the Board considered both mitigating and aggravating factors. The

Board noted that Lumumba's criminal history was extensive, and his prior

experiences with the probation system had not deterred him from other criminal

behavior. The Board also considered Lumumba's insufficient problem

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Related

Trantino v. New Jersey State Parole Board
764 A.2d 940 (Supreme Court of New Jersey, 2001)
Henry v. Rahway State Prison
410 A.2d 686 (Supreme Court of New Jersey, 1980)
Trantino v. NJ State Parole Bd.
752 A.2d 761 (New Jersey Superior Court App Division, 2000)
Bowden v. Bayside State Prison
633 A.2d 577 (New Jersey Superior Court App Division, 1993)
Wilfred Holmes v. Christopher Christie
14 F.4th 250 (Third Circuit, 2021)

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