Connecticut Dept. of Public Safety v. Doe

In Connecticut Dept. of Public Safety v. Doe (2003) 538 U.S. 1, the issue was whether public disclosure on Connecticut's Megan's Law Web site of a registered offender's name, photograph and other identifying information, deprived him of a liberty interest in his reputation and violated the due process clause of the Fourteenth Amendment by depriving him of a hearing to determine whether he was currently dangerous. The court held that since the Connecticut Legislature based the registration and disclosure requirements on the fact of previous conviction, rather than current dangerousness, "even assuming, arguendo, that respondent has been deprived of a liberty interest, due process does not entitle him to a hearing to establish a fact that is not material under the Connecticut statute." (538 U.S. at p. 7.) As the court noted, when registration and disclosure is based on the fact of conviction, the "offender has already had a procedurally safeguarded opportunity to contest." (Ibid.) The United States Supreme Court held that Connecticut's sex offender registration statute did not violated the due process rights of registrants. Because the ultimate fact determining whether a person had to register was conviction of sex crime, the Court found that the criminal procedures leading to conviction provided the registrant with a sufficient procedurally safeguarded opportunity to challenge the conviction that triggered the registration requirement. Id.