TRENTON, NJ – A federal judge in New Jersey has dismissed a lawsuit filed by a state prisoner who claimed he was entitled to monetary compensation for work credits he cannot use because of a mandatory minimum prison sentence.
U.S. District Judge Zahid N. Quraishi issued the ruling after screening the complaint of plaintiff Kenneth T. Hines, who is serving a 17-year term under New Jersey’s No Early Release Act (NERA). The law requires certain violent offenders to serve at least 85 percent of their sentence before becoming eligible for parole.
Hines argued that because NERA prevents him from fully applying any work credits earned in prison, he should instead receive financial compensation for those credits. He named as defendants the New Jersey Attorney General’s Office and Department of Corrections Commissioner Victoria Kuhn, but the court found his complaint failed to identify how either was directly responsible for the alleged harm.
Court finds no legal basis for compensation claim
Judge Quraishi dismissed the complaint without prejudice, meaning Hines may refile an amended version, but said the current filing did not state a plausible legal claim.
The court noted that inmates have no federal constitutional right to payment for prison labor and no vested property interest in work credits that have not yet been earned or applied. Citing prior rulings, the opinion stated that prisoners “may reasonably expect to be required to work without compensation as a result of their conviction.”
The judge also emphasized that even under liberal standards applied to self-represented litigants, Hines’ complaint lacked sufficient factual allegations to support a claim for relief.
Dismissal part of court’s required screening process
Because Hines was granted permission to proceed in forma pauperis—allowing him to file the case without paying fees—the court was required under 28 U.S.C. § 1915(e)(2)(B) to review the complaint for merit. The statute mandates that judges dismiss suits that are frivolous, malicious, fail to state a claim, or seek damages from immune defendants.
Judge Quraishi concluded that Hines’ request for compensation was rooted in dissatisfaction with the state statute itself, not any unconstitutional act by the defendants, and therefore did not establish a viable civil rights violation.
