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In the Interest of J.B.
107 A.3d 1
| Pa. | 2014
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Background

  • Seven juveniles adjudicated delinquent for specified sexual offenses were subject to SORNA’s lifetime registration on its effective date.
  • Trial court held SORNA unconstitutional as applied to juveniles under ex post facto, cruel punishment, and due process via irrebuttable presumption.
  • SORNA imposes substantial registration duties, in-person appearances, and penalties for noncompliance, with information shared across state and federal registries and public dissemination.
  • Statutory framework defines ‘‘juvenile offender’’ and applies to those aged 14+ who commit certain offenses, including post-2011 adjudications and those transferred from other jurisdictions.
  • Trial court found an irrebuttable presumption that all juvenile offenders pose a high risk of reoffense, burdening due process and reputation rights.
  • Commonwealth and Monroe County decisions are cited; the case Court consolidates issues and emphasizes tailored juvenile rehabilitation over blanket lifetime registration.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Does SORNA as applied to juveniles violate due process via irrebuttable presumption? Juveniles suffer repuation harm and lack opportunity to rebut the presumption. Legislature reasonably treats certain juveniles as high risk; protections exist and standardized procedures apply. Yes; unconstitutional due to irrebuttable presumption.
Does SORNA infringe the Pennsylvania Constitution right to reputation and due process for juveniles? Registration marks are a stigma that cannot be rebutted for many juveniles. Public safety and transparency justify registration as nonpunitive. Yes; violates reputation and due process rights.
Is there a reasonable alternative to lifetime registration for juveniles? Individualized risk assessment should determine need for ongoing registration. Current SOAB-based assessments and continued evaluations already exist. Yes; individualized risk assessment suffices as alternative.

Key Cases Cited

  • Commonwealth v. Clayton, 684 A.2d 1063 (Pa. 1996) (irrebuttable presumptions violate due process when not universally true and no meaningful rebuttal)
  • D.C. v. School Dist. of Philadelphia, 879 A.2d 408 (Pa. Cmwlth. 2005) (irrebuttable presumption in education violated due process for juveniles)
  • Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (juveniles are fundamentally different; cannot be treated as adults for punishment)
  • Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juvenile status requires different treatment in capital punishment context)
  • Weinberger v. Salfi, 422 U.S. 749 (U.S. 1975) (irrebuttable presumption doctrine limited by due process considerations)
  • Paul v. Davis, 424 U.S. 693 (U.S. 1976) (reputation is not protected absent a tangible interest)
  • Vlandis v. Kline, 412 U.S. 441 (U.S. 1973) (irrebuttable presumption issues and residency determinations require rebuttable process)
  • Bell v. Burson, 402 U.S. 535 (U.S. 1971) (due process requires meaningful opportunity to be heard before deprivation)
  • Dru Sjodin National Sex Offender Public Website v. United States, 42 U.S.C. § 16920 (N/A) (public sex-offender data and accessibility discussed)
Read the full case

Case Details

Case Name: In the Interest of J.B.
Court Name: Supreme Court of Pennsylvania
Date Published: Dec 29, 2014
Citation: 107 A.3d 1
Court Abbreviation: Pa.