## Facts

- C.K. was adjudicated delinquent in the mid-1990s for qualifying sex offenses committed as a juvenile.
- As a result of those juvenile adjudications, C.K. became subject to New Jersey’s Megan’s Law registration and community-notification requirements.
- New Jersey law generally permits termination of registration duties after 15 offense-free years upon proof the person is not likely to pose a threat (N.J.S.A. 2C:7-2(f)).
- A separate provision imposed a categorical, lifetime bar on any termination petition for specified offenses, including certain juvenile adjudications (N.J.S.A. 2C:7-2(g)).
- After decades offense-free and with evidence of rehabilitation, C.K. challenged subsection (g) as applied to juveniles under Article I, Paragraph 1 of the New Jersey Constitution.
- The lower courts rejected the challenge and held C.K. permanently ineligible to seek relief under subsection (f).

## Issues

1. Whether N.J.S.A. 2C:7-2(g)’s categorical, lifetime bar on termination petitions, as applied to juvenile adjudications, violates Article I, Paragraph 1 of the New Jersey Constitution (substantive due process).
2. If subsection (g) is unconstitutional as applied to juveniles, whether juvenile registrants may seek relief under N.J.S.A. 2C:7-2(f)’s 15-year petition process.

## Decision

- The Supreme Court of New Jersey reversed.
- The court held N.J.S.A. 2C:7-2(g) unconstitutional as applied to persons whose qualifying conduct occurred when they were juveniles.
- The court concluded the permanent bar, as applied to juveniles, lacked a rational relationship to Megan’s Law’s public-safety purpose because it foreclosed any later, individualized risk assessment.
- The court determined that juvenile registrants are instead governed by N.J.S.A. 2C:7-2(f) and may petition after 15 offense-free years by proving they are not likely to pose a threat to others.
- C.K. was entitled to pursue termination under subsection (f) consistent with its timing and proof requirements.

## Legal Principles

- Under Article I, Paragraph 1 of the New Jersey Constitution, a statutory classification affecting significant interests must at least satisfy rational-basis review by bearing a real and substantial relationship to a legitimate governmental objective.
- A statute that imposes an irrebuttable, permanent presumption of dangerousness on juvenile offenders—by denying any opportunity to petition for relief despite long-term offense-free conduct—fails rational-basis review as applied to juveniles.
- Megan’s Law’s termination mechanism in N.J.S.A. 2C:7-2(f) reflects legislative acceptance that risk can change over time and permits court-supervised, individualized assessment after a lengthy offense-free period.
- Invalidating subsection (g) as applied to juveniles does not create automatic relief; it restores eligibility to seek relief subject to judicial findings under subsection (f).

## Conclusion

The New Jersey Supreme Court held that Megan’s Law’s categorical lifetime bar on termination petitions is unconstitutional as applied to juvenile registrants because it irrationally forecloses any individualized showing of rehabilitation and current lack of risk; juvenile registrants may petition for termination under the statute’s 15-year, court-supervised process.


State in the Interest of C.K., 182 A.3d 917 (N.J. 2018)