Connecticut Dept. of Public Safety v. Doe (Connecticut Dept. of Public Safety v Doe)

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2003 United States Supreme Court case

Connecticut Department of Public Safety v. Doe, 538 U.S. 1 (2003), was a United States Supreme Court case regarding the constitutionality of the Connecticut sex offender registration requirement which required public disclosure of information on sex offenders after they had been released from incarceration.

Background

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A state statute required Connecticut 's Department of Public Safety (PDS) to collect information gathered from sex offenders who registered into a sex offender registry and publicize it on an Internet website and to make the registry available to the public in specific state offices, as Connecticut's version of Megan's Law .

The website contained the following disclaimer:

The registry is based on the legislature’s decision to facilitate access to publicly-available information about persons convicted of sexual offenses. [DPS] has not considered or assessed the specific risk of reoffense with regard to any individual prior to his or her inclusion within this registry, and has made no determination that any individual included in the registry is currently dangerous. Individuals included within the registry are included solely by virtue of their conviction record and state law. The main purpose of providing this data on the Internet is to make the information more easily available and accessible, not to warn about any specific individual.

John Doe, a convicted sex offender who was thereby subject to the law, filed suit in Federal court, claiming that the law violates the Fourteenth Amendment's Due Process Clause . The District Court issued an injunction regarding the law's public disclosure provisions. The Court of Appeals affirmed, concluding that such disclosure did indeed violate the Due Process Clause of the Fourteenth Amendment because registrants were not provided with a hearing prior to the public disclosure.

The Supreme Court granted certiorari to determine whether the United States Court of Appeals for the Second Circuit was correct in enjoining the public disclosure of Connecticut's sex offender registry .

Opinion of the Court

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In a unanimous opinion, the Second Circuit Court's judgment was reversed on the basis that due process does not require the opportunity to prove a fact that is not material to the State's statutory scheme. Injury to reputation in itself, even if defamatory, does not constitute deprivation of liberty.