On July 1, 2024, the New Jersey Supreme Court decided the Monmouth County case of IMO Registrant J.A. The principal issue before the Court under N.J.S.A. 2C:7-2 concerned the standard for Megan’s Law registration termination for juveniles.
The unanimous per curiam opinion reads as follows in relevant part: Because J.A. was adjudicated delinquent and not convicted of a sex offense, he is required to satisfy the public safety prong of subsection (f), not the offense-free prong. See In re Registrant R.H., ___ N.J. ___, ___ (2024) (slip op. at 3). Based on the reasoning of R.H. and the trial court’s finding that J.A. does not pose a safety threat, he is eligible for termination of his Megan’s Law obligations under subsection (f). We therefore reverse the judgment of the Appellate Division and remand the matter to the trial court to enter an appropriate order.
J.A. applied to terminate his Megan’s Law obligations. The trial court found that he was ineligible under subsection (f) because he had not remained offense-free after committing a predicate sex offense in 1999. The trial court also considered the public safety prong and found that J.A. satisfied it. The court explained that J.A. had been “productive and law-abiding” and had led “an exemplary life since” his juvenile adjudication. The court agreed with testimony from an expert psychologist that J.A. “present[ed] a very low risk to reoffend.” Nonetheless, the trial court stated it felt “constrained” by case law to deny the motion.
The Appellate Division affirmed. J.A. now argues to this Court that mandatory lifetime registration under subsection (f) is unconstitutional as applied to a registrant who committed a predicate sex offense as a juvenile and later commits another offense.
It is unclear how the requirements of Megan’s apply to a juvenile exempted from the statutory disclosure requirements of N.J.S.A 2A:4A-60f. The exemption prohibits disclosure of juvenile offender information to the public. One appellate panel concluded that the non-disclosure provisions do not override Megan’s Law, reasoning that Megan’s Law was adopted with presumed knowledge of the Juvenile Code and that the more specific law must prevail over the general one.
