Muhammad v. Balicki

In Muhammad v. Balicki, 327 N.J.Super. 369, 372, 743 A.2d 376 (App.Div.2000), the prisoner was placed on "reduced custody status," which we acknowledged "enables a prisoner to enjoy more mobility and less supervision in the prison than the general prison population." However, under an amendment of the regulation at issue, Muhammad did not receive reduced custody status in 1999. The Court observed that, "while the 'atypical and significant hardship' standard of Sandin may be difficult to define citation omitted, it is clear to us that the loss of enjoyment of greater mobility than that accorded to the general prison population and less supervision . . . do not fall within that standard. . . ." Id. at 372-373, 743 A.2d 376.