H.R. v. New Jersey State Parole Board (N.J. 2020)

H.R. v. New Jersey State Parole Board, No. 082373 (N.J. 2020)

Nature of Case: Appellant was convicted of a sex offense and sentenced to a term that included parole supervision for life. Upon release, the New Jersey State Parole Board designated Appellant as a Tier III sex offender and required the imposition of GPS monitoring. Appellant objected on the grounds that it was an unconstitutional search, and the trial court rejected the challenge. Appellant sought review.

Holding: New Jersey Supreme Court held that while the GPS monitoring was a search and thus implicated the 4th Amendment, it was justified in the particular instance of a Tier III offender on parole supervision for life on the grounds of the special needs exception to the warrant requirement. Thus, the Court affirmed the decision of the lower court.