New Jersey Inmate’s Workers’ Compensation Claim Fails to Meet Cut in Court

Case File

While workers' compensation law sometimes covers surprising circumstances, a New Jersey case made clear that an inmate's claim about his barbershop job wasn't within the Workers' Compensation Act's reach. Simply Research subscribers have access to the full text of the case.

Case

Johnny v. New Jersey Department of Corrections, No. A-0297-23 (N.J. Super. Ct. 08/05/25, unpublished)

What Happened

An inmate at a New Jersey state prison worked as a barber, earning $2.50 per day. Allegedly, he was offered an assignment in the officers' barbershop, where he would have earned $6 per day but, while provisionally assigned to this role, he was paid as a unit barber.

After filing a grievance, the inmate was terminated from the officers' barbershop. The inmate filed several more grievances until he "quit."

The New Jersey Department of Corrections denied his final grievance, and the inmate appealed to court, arguing that, under the state's Workers' Compensation Act, he should be paid for his provisional assignment in the officers' barbershop, and even if he voluntarily resigned, the DOC had a duty to pay him for his labor.

Rule of Law

In New Jersey, the Workers' Compensation Act governs compensation for work-related injuries arising out of and in the course of employment. New Jersey courts 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," as expressed in Henry v. Rahway State Prison, 81 N.J. 571 (1980).

What the Court Said

The court didn't find much traction in the inmate's workers' compensation argument.

"[The inmate's] reliance on the workers' compensation statute is misplaced, as neither his grievance nor his appeal arises from a work-related injury and therefore falls outside the scope of that statute," the court wrote.

The court also found that the inmate had no liberty interest in the provisional assignment in the officers' barbershop, and therefore, that provisional assignment's wages did not provide him with a basis for asserting a viable claim for relief.

Verdict: The court upheld the DOC's administrative ruling.

Takeaway

An inmate's claim about being denied a position falls outside the scope of New Jersey's Workers' Compensation Act.

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