A federal appeals court ruled that a state-employed psychologist can't be sued by her patient, a convicted sex-offender, over claims that she retaliated against him for his paralegal work while committed.

Lorenzo Oliver—civilly committed to New Jersey's Special Treatment Unit for violent sexual predators—sued psychologist Debra Roquet claiming she would not advance him to the next stage of treatment because of his legal work for other detainees, in violation of his free speech rights.

In a progress report, Roquet claimed Oliver's intense focus on paralegal services took his attention away from rehabilitation. She also based her decision to hold Oliver back on his hostility toward facility staff and manipulating other inmates by charging for legal work.