The Appellate Division of the Supreme Court of the State of New York has upheld a disciplinary ruling against Jerome Mack, an inmate at Wallkill Correctional Facility. The court's decision, made on November 5, 2026, confirms that Mack was guilty of making false statements and obstructing visibility, following a complaint he filed under the Prison Rape Elimination Act (PREA). This ruling affects not only Mack but also sets a precedent for how similar cases may be handled in the future.

The case, officially titled Matter of Mack v. Martuscello, was prompted by a misbehavior report filed against Mack. The report claimed that he had made false allegations against a correction officer, asserting that the officer had refused to allow him access to the law library because he had covered his cell with a sheet. Mack alleged that the officer had pulled down the sheet and stared at him while he was naked, which he claimed made him uncomfortable.

The situation escalated when an investigation was launched, involving video footage from both fixed cameras and a body-worn camera assigned to the correction officer. The investigation revealed that Mack's claims were unfounded. The footage showed that the officer did not pull down the sheet and that Mack had not expressed that he was naked. Consequently, Mack was charged with violating prison disciplinary rules.

During a tier II disciplinary hearing, Mack was found guilty of both charges. This finding was upheld upon administrative appeal, leading to the current court proceeding under CPLR article 78, which allows individuals to challenge the determinations of administrative agencies.

The court ruled that the evidence against Mack was substantial. In its opinion, the court stated, "The misbehavior report, hearing testimony and video of the incident provide substantial evidence supporting the determination of guilt." The judges involved in the decision included Garry, P.J., Reynolds Fitzgerald, Ceresia, McShan, and Ryba, JJ.

The court also addressed Mack's claims that the misbehavior report was written in retaliation for his PREA complaint. The judges noted that this created a credibility issue for the Hearing Officer to resolve. They stated, "Petitioner's contention that the misbehavior report was written in retaliation for the PREA complaint created a credibility issue for the Hearing Officer to resolve." Ultimately, the court found no merit in Mack's arguments.

Additionally, Mack argued that he should not have been charged until facility staff attempted to de-escalate the situation, as outlined in Correction Law § 138 (7). However, the court clarified that this provision does not protect an inmate from being charged when they intentionally file a false misconduct report. The court noted, "This provision, however, does not shield an incarcerated individual from being charged in a misbehavior report where, as here, he intentionally filed a false misconduct report resulting in an internal and unnecessary investigation."

The court also rejected Mack's procedural claims, including his assertion that the Hearing Officer improperly denied his requests for witnesses. The judges determined that the proposed witnesses would have provided irrelevant or redundant testimony. They concluded that the Hearing Officer did not abuse their discretion in classifying the misbehavior report as tier II, given the seriousness of the charges.

In summary, the Appellate Division confirmed the disciplinary ruling against Mack, emphasizing the importance of maintaining order and integrity within correctional facilities. The ruling serves as a reminder that false allegations can have serious consequences, not only for the accused but also for the overall functioning of the prison system.

The impact of this ruling extends beyond Mack's individual case. It reinforces the standards for handling complaints within correctional facilities and highlights the importance of thorough investigations when allegations are made. This decision may influence how future cases of alleged misconduct are approached, particularly in terms of the evidence required to substantiate claims.

Looking ahead, it is unclear whether Mack will seek to appeal this decision. The court filing did not provide information on any potential related cases or further legal actions that may arise from this ruling. However, the outcome of this case could serve as a reference point for similar situations in the future.