WALLACE v. NEW JERSEY DEPARTMENT OF CORRECTIONS

CourtDistrict Court, D. New Jersey
DecidedFebruary 28, 2025
Docket1:24-cv-11539
StatusUnknown

This text of WALLACE v. NEW JERSEY DEPARTMENT OF CORRECTIONS (WALLACE v. NEW JERSEY DEPARTMENT OF CORRECTIONS) 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
WALLACE v. NEW JERSEY DEPARTMENT OF CORRECTIONS, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

JOSEPH WALLACE, Plaintiff, Civil Action No, 24-11539 (SMW) (EAP) v. OPINION NEW JERSEY DEPARTMENT OF CORRECTIONS, et al., Defendants.

WILLIAMS, District Judge: This matter comes before the Court on the Court’s sua sponte screening of Plaintiffs complaint (ECF No. 1) and the Court’s review of Plaintiffs application to proceed im forma pauperis (ECF No. 4). Having reviewed the application, this Court finds that leave to proceed in pauperis is warranted in this matter, and the application is granted. Because Plaintiff shall be granted in forma pauperis status in this matter, this Court is required to screen his complaint pursuant to 28 U.S.C. § 1915(e)(2)(B) and dismiss any claim which is frivolous, malicious, fails to state a claim for relief, or seeks relief from an immune defendant, For the reasons set forth below, Plaintiff's complaint is dismissed without prejudice for failure to state a claim for which relief may be granted.

1. BACKGROUND Plaintiff is a state prisoner currently confined at East Jersey State Prison. (ECF No. 1 at 3- 4.) In November 2024, several officers searched Plaintiff cell and recovered USB drives and other

electronic paraphernalia which Plaintiff admits were contraband and contained pornographic images. Ud. at 7-8.) Although Plaintiff contends that the images were of adults, he alleges that in their reports and charging documents for Plaintiff's resulting disciplinary charges, the individual Defendants — all of whom are corrections officers — stated that they believed the images were in fact child pornography, Ud. at 4-8.) Plaintiff contends that these allegedly false allegations were defamatory and violated his rights, resulting in the imposition of harsh sanctions including 300 days of solitary confinement and 300 days loss of commutation credits following his disciplinary hearing. Ud.) Plaintiff does not appear to allege he was denied Due Process at the resulting hearing as he raises claims only against the officers who prepared and approved the charging reports and the NJ Department of Corrections itself, and does not raise a claim against the hearing officer. Ud.)

IL. LEGAL STANDARD Because Plaintiff shall be granted in forma pauperis status, this Court is required to screen his complaint pursuant to 28 U.S.C. § 1915(e)(2)(B). Pursuant to the statute, this Court must sua sponte dismiss any claim that is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. Jd. “The legal standard for dismissing a complaint for failure to state a claim pursuant to 28 U.S.C. § 1915{e)(2)(B)Gi) is the same as that for dismissing a complaint pursuant to Federal Rule of Civil Procedure 12(b)(6).” Schreane v. Seana, 506 F. App’x 120, 122 Gd Cir. 2012) (citing Allah v. Seiverling, 229 F.3d 220, 223 (3d Cir. 2000)). In deciding a motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6), a district court is required to accept as true all factual allegations in the complaint and draw all reasonable inferences from those allegations in the light most favorable to the plaintiff, see Phillips v. Cnty. of Allegheny,

”y

515 F.3d 224, 228 Gd Cir. 2008), but need not accept as true legal conclusions couched as factual allegations. Papasan v. Allain, 478 U.S. 265, 286 (1986). A complaint need not contain “detailed factual allegations” to survive a motion to dismiss, but must contain “more than an unadorned, the- defendant-unlawfully-harmed-me accusation.” Ashcroft v. Igbal, 556 U.S. 662, 678 (2009). A complaint “that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do,’” and a complaint will not “suffice” if it provides only “’naked assertion|s]’ devoid of ‘further factual enhancement.’” Jd. (quoting Bell Atlantic v. Twombly, 550 U.S. 544, 555, 557 (2007)). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.” Jd (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” fd. (quoting Twombly, 550 U.S. at 556). A complaint that provides facts “merely consistent with” the defendant’s liability “stops short of the line between possibility and plausibility” and will not survive review under Rule 12(b)(6). Jd. (quoting Twombly, 555 U.S. at 557}. While pro se pleadings are to be liberally construed in conducting such an analysis, pro se litigants must still “allege sufficient facts in their complaints te support a claim.” Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir, 2013).

Ii. DISCUSSION In his complaint, Plaintiff contends that his rights were violated when officers filed charging reports indicating that the contraband seized from Plaintiffs cell contained not just pormographic images, which Plaintiffadmits, but child pornography. Essentially, Plaintiff believes his rights were violated by the allegedly false assertions in the reports. “[T]he act of filing false disciplinary charges does not itself violate a prisoner’s constitutional rights.” Poole v. Mercer

Cnty. Corr. Ctr., No. 11-3730, 2012 WL 694689, at *2 (D.N.J. Feb, 29, 2012); see also Mimms v, TICO.R., 386 F. App’x 32, 36 3d Cir, 2010) (the “filing of false disciplinary charges does not constitute a claim under § 1983 so long as the inmate was granted a hearing and an opportunity to rebut the charges”); Smith v, Mensinger, 293 F.3d 641, 653-54 (3d Cir, 2002), Instead, it is only a denial of Due Process in resulting hearings which could support a constitutional claim, Adimim, 386 F. App’x at 36. Here, Plaintiff does not appear to be directly alleging a denial of Due Process and instead raises only the issue of the allegedly false details in the disciplinary reports. As Defendants allegedly only prepared and filed partially false reports, their actions do not amount to a constitutional violation and Plaintiff therefore fails to state a claim for relief. Even were this Court to construe Plaintiff to be raising a Due Process claim, however, Plaintiff would be barred from raising such a claim at this time as the result of his hearing was a loss of 300 days of commutation credits, a harsh sanction Plaintiff directly connects to the claims that the pornography he possessed included images of children, and success on any Due Process claim related to his hearing would therefore impugn the validity of the current length of Plaintiff's sentence. In Heck v. Humphries, 512 U.S. 477

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Related

Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Wilkinson v. Dotson
544 U.S. 74 (Supreme Court, 2005)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Reginald Mimms v. UNICOR
386 F. App'x 32 (Third Circuit, 2010)
Michael Malik Allah v. Thomas Seiverling
229 F.3d 220 (Third Circuit, 2000)
Clarence Schreane v. Seana
506 F. App'x 120 (Third Circuit, 2012)
Kelley Mala v. Crown Bay Marina
704 F.3d 239 (Third Circuit, 2013)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Grabow v. Southern State Correctional Facility
726 F. Supp. 537 (D. New Jersey, 1989)
Smith v. Mensinger
293 F.3d 641 (Third Circuit, 2002)

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WALLACE v. NEW JERSEY DEPARTMENT OF CORRECTIONS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wallace-v-new-jersey-department-of-corrections-njd-2025.