Supreme Court of New Jersey

Charles Jenkins, Lloyd Muhammad, Edward R. Williams, John King, Ra’d Abdul-Ramim Muhammad, Henry T. Mulka, Randolph…

July 27, 1987108 N.J. 239

Summary

The New Jersey Supreme Court held that the Commissioner’s emergency reclassification of homicide‑convicted inmates from full minimum to either “full minimum — inside only” or “gang minimum” did not create a protected liberty interest and therefore did not require the procedural safeguards of Wolff v. McDonnell; the Court affirmed the Appellate Division’s ruling on the “inside only” classification and reversed its requirement of a hearing for the gang‑minimum classification, directing the Department to amend its regulations accordingly.