State v. Dickerson
Meghan's Law, which requires all convicted sex offenders to register, does not violate the Equal Protection rights of a nonviolent offender. Allegedly, the defendant engaged in sexual intercourse with a mentally defective victim, who was unable to consent. The defendant pled guilty under the Alford doctrine. After his release from prison, the defendant became active in church and worked as a machinist and a helicopter inspector. The defendant completed five years of private counseling and sex offender treatment, passed polygraph tests and had his computer searched for inappropriate material. Because he was convicted of second-degree sexual assault, which is classified as a sexually violent offense, the defendant was required to register for life as a sexual offender. Individuals who commit second-degree sexual assaults against minors are only required to register for 10 years. Dickerson objected that the lifetime registration requirement prevents him from being considered for management positions at Sikorsky and violates the Equal Protection Clause, because it treats different types of second-degree sexual assault differently. Dickerson claimed that registration is needlessly harsh when an individual has rehabilitated. The purpose of Meghan's Law is to protect children and alert the public, by identifying sexual offenders who commit acts that are predatory. Convicted sex offenders do not qualify as a protected class of individuals. Dickerson did not allege a violation of a fundamental right. Under rational basis review, a statute will be sustained, if a classification is rationally related to a legitimate state interest. The court rejected Dickerson's equal protection challenge. "The defendant," wrote the court, "has failed to demonstrate that there is no rational basis for the difference between the registration requirements for those convicted of second degree sexual assault involving minors and those convicted of sexually violent offenses." The lifetime registration requirement was not punitive in purpose, and it did not violate the Ex Post Facto Clause, because it was ordered after the defendant's conviction. The law has a rational connection to the nonpunitive purpose of public safety. The court denied the defendant's request for an exemption from the requirement that he register as a sex offender for life.