J.I. v. New Jersey State Parole Board(076442), 155 A.3d 1008

Background

J.I., convicted of sexual assault and endangering minors, was subject to Community Supervision for Life (CSL) after release; initial written CSL condition only barred creating social‑networking profiles without supervisor approval.
After a 2010 discovery of child‑nude images on his computer (pre‑CSL period), Parole initially restricted internet use and jailed him for possessing an Internet‑capable phone; he was later released in 2012 and complied with CSL conditions for ~13 months.
In 2013 J.I. requested LinkedIn access; the District Parole Supervisor then imposed a near‑total ban (internet only for employment, with monitoring), and a Board panel affirmed the restriction.
J.I. accessed benign, non‑work sites (church, therapist, consumer sites); parole authorities escalated to a complete ban on possessing any Internet‑capable device; the Parole Board denied a hearing.
The Appellate Division upheld the Board; the Supreme Court of New Jersey granted certification and reversed, remanding for a hearing and instructing that Internet restrictions must be reasonably tailored and supported by penological objectives.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a total Internet ban imposed on a CSL offender was unconstitutionally overbroad	J.I.: total ban not narrowly tailored, unrelated to his offenses, unduly restricts reintegration and free expression	Parole Bd.: restrictions are permissible special conditions tied to public safety and rehabilitation; panel review sufficed	Court: ban was overbroad here; less restrictive alternatives existed and total ban not justified
Whether access to the Internet/computer implicates a protected liberty interest requiring due process	J.I.: lifetime/comprehensive ban implicates liberty interests and employment/communication needs, triggering hearing rights	Parole Bd.: condition is supervision‑related and did not trigger heightened process beyond notice/opportunity to object	Court: Internet access implicates liberty interests; due process (notice and opportunity to be heard) required before/after severe restrictions
Whether parole authorities denied adequate procedural protections when imposing the ban	J.I.: was denied meaningful opportunity to submit written materials and to appear before Board after drastic restriction	Parole Bd.: J.I. received notice and could appeal; no evidentiary hearing necessary	Court: CSL offenders must be allowed to submit written responses to panel (10–15 days) and, given circumstances, J.I. must be allowed to appear before full Board
Proper scope/standards for tailoring Internet conditions on CSL offenders	J.I.: conditions must be individualized, tied to offense/risk, and the least‑restrictive effective measures used	Parole Bd.: has discretion to impose conditions based on offender history to protect public and aid rehabilitation	Court: conditions must be reasonably related to reducing recidivism/public safety and use less‑restrictive means (monitoring, inspections) when suitable

Key Cases Cited

Morrissey v. Brewer, 408 U.S. 471 (1972) (parole supervision implicates due process protections)
Mathews v. Eldridge, 424 U.S. 319 (1976) (balancing test for required procedural protections)
United States v. Voelker, 489 F.3d 139 (3d Cir.) (internet restrictions must be tangibly related to offense/history)
United States v. Miller, 594 F.3d 172 (3d Cir.) (internet access essential; conditions must be supported by evidence tying restriction to sentencing goals)
United States v. Albertson, 645 F.3d 191 (3d Cir.) (blanket internet bans can be overbroad; prefer monitoring/inspections when appropriate)
Jamgochian v. New Jersey State Parole Board, 196 N.J. 222 (2008) (CSL offender entitled to hearing before imposition of onerous curfew condition; applied Mathews balancing)
J.I. v. N.J. State Parole Bd., 441 N.J. Super. 564 (App. Div. 2015) (Appellate Division opinion upholding Board, later reversed)