Compassionate Release Act Does Not Require Physical Examination of Inmates Seeking Relief, But Denial of Relief in This Case Was Arbitrary and Capricious

M.R. v. New Jersey Department of Corrections, ___ N.J. ___ (2025). Plaintiff appealed the denial of his petition for release under the Compassionate Release Act, N.J.S.A. 30:4-123.51 (“CRA”). He argued that he had not been physically examined by a physician, and that the statute required a physical examination. The Appellate Division determined that the statute did not require a physical examination and upheld the denial of compassionate release. Today, in a unanimous opinion by Justice Hoffman, the Supreme Court agreed that no physical examination was required, but reversed the denial of compassionate relief as insupportable.

As Justice Hoffman observed, after the Appellate Division ruled, in an opinion reported at 478 N.J. Super. 377 (App. Div. 2024), plaintiff both petitioned the Supreme Court for certification and supplemented his petition for compassionate relief with more evidence, “most significantly, that an MRI scan conducted on May 12, 2024, revealed the recurrence of [a] brain tumor. On May 28, 2024, M.R. reapplied for compassionate release and he was granted a Certificate of Eligibility on June 7, 2024. Ten days later, before he was able to petition the Superior Court for release, M.R. died.” Despite that, the Supreme Court granted certification thereafter.

It did not appear difficult for the Court to affirm the Appellate Division’s ruling that the CRA did not require a physical examination as a basis for decision regarding compassionate release. Justice Hoffman noted that although the statute calls for a “medical diagnosis,” neither the CRA itself nor its implementing regulation, which refers to an “examination,” expressly mandated a physical examination, and “both parties concede[d]” that.”

The Court cited dictionary definitions of “diagnosis,” which made no mention of a “physical” examination. Moreover, “[i]f the Legislature intended that diagnoses be rendered solely through ‘physical’ examinations, it would have stated as much, as it has done on numerous other occasions,” Justice Hoffman said, citing a number of other statutes. Nor did “examinations” in the implementing regulation rescue the argument for a requirement of a physical examination. Again, dictionary definitions and other regulations that expressly identified a particular type of examination disposed of the issue. “Once again, had [defendant] intended to include such a qualifier, it could have very easily done so.”

Though recognizing that judicial review of agency action is deferential, the Court went on to hold that the record did not support the denial of compassionate release and was arbitrary, capricious, and unreasonable. Justice Hoffman gave some guidance “[m]oving forward” as to the sort of explanation that the Department of Corrections and medical personnel should provide in order to support the grant or denial of compassionate release.

Plaintiff’s death before this appeal was heard had at least two consequences for this case. First, Justice Hoffman said that although the case was “technically” moot upon his death, the Court would rule anyway because the matter “raise[d] issues that “are of substantial importance and are capable of repetition, yet evade review,” as CRA applicants might die before their cases are finally adjudicated. Second, plaintiff’s death led to a final decision of arbitrariness in his own case, rather than a remand for further proceedings., Justice Hoffman said. “Had we been afforded the opportunity to review this decision prior to subsequent developments in the case -- namely, M.R.’s passing -- we would have remanded the matter back to the DOC and directed it to conduct a more comprehensive and contemporaneous evaluation.”

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Compassionate Release Act Does Not Require Physical Examination of Inmates Seeking Relief, But Denial of Relief in This Case Was Arbitrary and Capricious

M.R. v. New Jersey Department of Corrections, ___ N.J. ___ (2025). Plaintiff appealed the denial of his petition for release under the Compassionate Release Act, N.J.S.A. 30:4-123.51 ("CRA"). He argued that he had not been physically examined by a physician, and that the statute required a physical examination. The Appellate Division determined that the statute did not require a physical examination and upheld the denial of compassionate release. Today, in a unanimous opinion by Justice Hoffman, the Supreme Court agreed that no physical examination was required, but reversed the denial of compassionate relief as insupportable....