J.I. v. New Jersey State Parole Board, 120 A.3d 256

J.I. is a convicted sex offender serving CSL under Megan's Law framework and monitored by the Board.
CSL conditions include internet/computer restrictions, social networking prohibition, pornography restriction, and alcohol restrictions, evaluable for modification.
In 2009–2010, J.I. was allowed a limited modification for employment-related internet use with monitoring, which was later revoked after violations.
The Board adopted a general social networking prohibition (N.J.A.C. 10A:71-6.11(b)(22)) in 2010, modifiable by a DPS upon showing rehabilitative progress.
J.I. violated modified conditions by accessing non-employment websites and possessing pornographic material; revocation led to renewed internet ban.
The Board upheld the information-based grounds for the ban, and J.I. appealed challenging facial validity, due process, ex post facto, and hearing rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Facial validity of social networking rule	J.I. argues the ban is overbroad and unconstitutional.	Board argues it targets dangerous online interactions and is tailored to public safety and rehabilitation.	Rule facially valid; permits case-by-case modification and is constitutionally permissible.
Due process and notice for conditions/modifications	J.I. asserts lack of meaningful notice/hearing rights.	J.I. received notice, opportunity to object, and a path to modification; due process satisfied.	No due process violation; procedures adequate for CSL context.
Ex post facto challenge to 2010 amendment	Amendment imposes punitive changes retroactively.	Amendment remedial, not punitive, aimed at safety and rehabilitation.	No ex post facto violation; amendment remedial and non-punitive.
Administrative arbitrariness of Board's upholding conditions	Conditions are arbitrary and not related to rehabilitation or public safety.	There is a substantial record linking conditions to prior offenses and risk reduction.	Board's decision not arbitrary; supported by substantial evidence and proper standards.
Right to discovery/hearing regarding CSL conditions	J.I. seeks discovery and a hearing on conditions.	Full trial rights are not required; statutory due process suffices for CSL.	No entitlement to additional discovery/hearing beyond due process standards.

J.B. v. N.J. State Parole Bd., 433 N.J. Super. 327 (App. Div. 2013) (due process and notice; access to internet for rehabilitation; modification path)
Pazden v. N.J. State Parole Bd., 374 N.J. Super. 356 (App. Div. 2005) (reasonableness of conditions and rehabilitation focus)
Doe v. Poritz, 142 N.J. 1 (1995) (megan's law and non-punitive registration/notification not punishment)
Jamgochian v. N.J. State Parole Bd., 196 N.J. 222 (2008) (parolee rights and flexible due process standards)
State v. Perez, 220 N.J. 423 (2015) (CSL/punitive vs remedial analysis; retroactivity considerations)
State v. Schubert, 212 N.J. 295 (2012) (punitive nature of CSL and retroactivity implications)