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Abstract: 

Our review of recent appellate decisions includes People v. Dulac, in which the Colorado Court of Appeals ruled a sex offender was not eligible to seek early removal from Colorado’s sex offender registry, even though he had successfully completed a deferred adjudication of his sexual assault charge; Matter of R.S., a case from New Jersey ruling that a Megan’s Law registrant is entitled to an evidentiary hearing if the registrant demonstrates a genuine issue of material fact exists about whether the registrant’s conduct is characterized by a pattern of repetitive and compulsive behavior; and Doe v. Sex Offender Registry Board, a Massachusetts Court of Appeals ruling that an offender’s classification as a level 3 sex offender was proper after a hearing examiner had engaged in the required qualitative and objective review that balanced all the relevant risk-aggravating and mitigating factors.

Keywords: Early Removal from Registry; Evidentiary Hearings in Determining Compulsive Behavior; Classification

Affiliations:  1: Sex Offender Law Report.