Jones v. County of Suffolk et al. (2nd Cir. 2019)

Jones v. County of Suffolk et al., No. 18-1602– cv (2nd Cir. 2019)

Nature of Case: Plaintiff, who had been required to register as a sex offender, brought a § 1983 federal civil rights lawsuit challenging the constitutionality of compliance visits that were conducted by Parent’s for Megan’s Law — a private organization that contracted with law enforcement to send civilians to conduct residential visits to the homes of people on the registry. Plaintiff alleged that the visits violated his Fourth Amendment rights. The federal district court dismissed the lawsuit, finding that the visits were constitutional under the special needs doctrine. Plaintiff appealed.

Holding: The 2nd Circuit Court of Appeals affirmed. The Court held that, even assuming that the visits constituted seizures within the meaning of the Fourth Amendment, that they were justified under the special needs doctrine. The Court based its holding, in part, on the Supreme Court decisions of McKune v. Lile and Smith v. Doe, for the proposition that people on the registry had a high rate of recidivism, and thus that the seizures were not unreasonable.