New Jersey Supreme Court Decision – Megan’s Law 

On July 1, 2024, the New Jersey Supreme Court decided In re Registrant R.H., 258 N.J. 1 (2024), which clarified the application of N.J.S.A. 2C:7-2(f), the 15-year offense-free requirement under Megan’s Law, N.J.S.A. 2C:7-1 to -23, for juveniles adjudicated delinquent. The Court held that the requirement to remain offense-free for 15 years does not apply to juveniles adjudicated delinquent in family court, it only applies to juveniles prosecuted as adults. 

Facts and Procedural History: Megan’s Law Requirements 

The consolidated appeal involved two juveniles, R.H. and T.L., who were adjudicated delinquent for aggravated sexual assault. Both sought to terminate their registration and community notification requirements imposed under Megan’s Law. R.H. was adjudicated delinquent in 2009 and has been offense-free since. T.L. was adjudicated delinquent in 2005 and was later convicted of a petty disorderly person’s offense in 2015. The trial courts denied their motions, finding the 15-year waiting period had not elapsed. The Appellate Division affirmed. The New Jersey Supreme Court granted certification to review the cases. 

Legal Issues and Holdings: Juvenile Adjudication Under Megan’s Law 

The Court’s decision centered on the interpretation of N.J.S.A. 2C:7-2(f), which outlines the conditions for terminating Megan’s Law registration. The statute requires that the individual has not committed an offense within 15 years following conviction or release from a correctional facility and that they are not likely to pose a threat to public safety. However, the statute uses the terms “conviction” and “release from a correctional facility,” which traditionally apply to adults or juveniles tried as adults, not juveniles adjudicated delinquent. 

Reasoning of the Court: Megan’s Law and Juvenile Delinquency 

In its analysis, the Court distinguished between “conviction” and “adjudication of delinquency,” noting that these are legally distinct concepts within the juvenile and adult criminal justice systems. The Court emphasized that the plain language of the statute applies the 15-year offense-free requirement to those convicted of an offense, not to those adjudicated delinquent in Family Court. The Court’s decision was grounded in the plain language of the statute, where the Legislature deliberately excluded “adjudicated delinquent” from the conditions triggering the 15-year offense-free requirement. 

Conclusion: Key Takeaways from the Megan’s Law Decision 

The New Jersey Supreme Court ruled that juveniles adjudicated delinquent are not subject to the 15-year offense-free requirement under Megan’s Law, as this requirement applies only to those convicted. However, these individuals must still demonstrate that they do not pose a threat to public safety to terminate their registration obligations. This decision clarifies the application of Megan’s Law to juveniles and emphasizes the distinct treatment of juvenile adjudications compared to adult convictions. 

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