Friday, March 31, 2017

How Much has Virginia Spent on Managing and Monitoring Their Registered Sex Offenders From 2005 to 2016? $63.2 Million

As long time readers/followers know I’ve been submitting FOIA requests to the Virginia State Police for the last 8 years to track growth, classifications, categories of RSO’s and costs of the VSP Registry. The majority of my VSP FOIA requests are denied under Virginia’s ridiculous FOIA rules but one FOIA I know I’ll always get an answer on is the annual costs for the State Police to monitor and manage our RSO’s. 

I have to pay a fee ($44.98 for the 2016 numbers) for the VSP to pull the data I’ve asked for, but it’s worth it in my opinion. 

So in 2016 the cost of the USPS certified letter went down to $10.06 per letter but there was a 5% increase in the number of letters that went out in 2016. All-in-all the VSP is claiming a 2.01% drop in costs for 2016 from 2015’s numbers. 

But for the first time I decided to tally the total spent by the VSP over the last 11 years and that comes to $63,279,920.79 ….Wow! 

And remember approximately 40% of the entire RSO population are actually “under VSP supervision”. Approximately 20% is incarcerated and the other 40% are officially under VA-DOC Probation supervision but yet the VSP mails their letters out and takes their re-registrations and data updates. So 60% of the RSO population is costing the VA-DOC millions of dollars per year too.
What a waste of resources and money when this population has a 3-12% recidivism rate. 

Mary Devoy

Thursday, March 30, 2017

Legislative Goal #2 for a Smarter Sex Offender Registry in Virginia – Correct 2 Virginia Statutes with Known Errors (VA Code v. Hours of Operation) Making RSO Compliance Extremely Difficult and Many Times a Felony

I’m posting 1 to 2 of my newly redrafted Legislative Goals for a Smarter Sex Offender Registry in Virginia , one at a time through mid-May. Not only to highlight each one but hopefully to inspire you readers/followers to speak up and ask your one Virginia Delegate and one Senator to Patron/Sponsor a Bill at the next Virginia General Assembly session in January 2018.

Our VA GA. sessions begin the second Wednesday of every January so you should make your request somewhere between May and early-November. You could do it via email, via phone or even schedule a meeting with your Delegate and Senator to discuss the issues that concern you as their constituent and then propose a Bill or two at that meeting.

If they decline to Patron/Sponsor the Bill, ask them why.  

If their concerns can be addressed, address them. If not let them know you’ll be in a touch again in a month or 2, then pick a different goal and ask them to sponsor that new proposal and if they decline, again ask them why. If their new concerns for the second request can be addressed, address them. 

Tuesday, March 28, 2017

6th Circuit Courts Decision on Michigan Case Snyder v. Doe was “Reviewed” by SCOTUS on Friday March 24 then on Monday SCOTUS Asked the Solicitor General to Weigh in Before They Reach a Decision

There isn’t a lot of information about this SCOTUS “Review” that occurred last Friday for me to share here.
So I’m posting the below links for anyone who is interested in the Michigan case of Snyder v. Doe that asks Are Sex Offender Laws Punishment? The 6th Circuit Court said, YES. Then the case made it to the U.S. Supreme Court not to be “heard” but to be “reviewed”. Now SCOTUS has asked the Solicitor General to weigh in before they reach a decision.
Mary Devoy 

Supreme Court asks for input of Solicitor General; what does this mean? March 27, 2017
·               Today’s orders – Two grants, one CVSG, still no Masterpiece Cakeshop
SCOTUS to consider MI’s Snyder v. Doe 6th Circuit decision, March 24, 2017
Are Sex Offender Laws Punishment?

Past articles on Snyder v. Doe:
·               Sex offender laws and the 6th Circuit’s Ex Post Facto Clause ruling, September 7, 2016
·               The 6th Circuit Finally Said The Magic Word: Punitive, August 25, 2016
·               Court says Michigan sex offender registry laws creating ‘moral lepers’, August 26, 2016
·               6th Circuit Says Mich. Sex Offender Registry Is Punitive and, Not Incidentally, Stupid August 26, 2016
·               Court voids state sex offender registry for imposing unconstitutionally retroactive punishment , August 25, 2016

Monday, March 27, 2017

Legislative Goal #1 for a Smarter Sex Offender Registry in Virginia - Remove the Employer/Company Name AND the Street Address from the Online VSP Sex Offender Registry

New Brochure for 2017, Just Ordered Them Today!
As you most likely already know, I completely redrafted my Legislative Goals for a Smarter Sex Offender Registry in Virginia on March 22, 2017. 

Now I’m going to post 1 to 2 of those goal per week, one at a time until mid-May to not only highlight each one but hopefully to inspire you readers/followers to speak up and ask your one Virginia Delegate and one Senator to Patron/Sponsor a Bill at the next Virginia General Assembly session in January 2018. 

Wednesday, March 22, 2017

New Legislative Goals for a Smarter Sex Offender Registry in Virginia

Originally I had 28 Legislative Goals, now I’ve settled on 13. 

A few more may follow over the next few weeks but these  are my priority. 

I hope you’ll pick one or two and ask your one Virginia Delegate and one Senator before mid-November to patron one in January 2018. 

This is what I’ll be working on from May 2017 until after November selection for the entire Virginia House.

Mary Devoy

Tuesday, March 21, 2017

HB1485: Virginia’s Residency Restrictions and Loitering Laws for Those Listed on the VSP Sex Offender Registry


Well thank goodness; VA Senator Deeds was honest about where 2017’s HB1485/SB1072 actually came from, the Virginia State Police! Unlike Delegate Dickie Bell’s “constituent” claim. 

If you patron a Bill, own where it came from, what the true intent was, what the collateral consequences are and how about who raised the alarm on it's issues.


McAuliffe signs sex offender bill, March 22, 2017
New law expands qualifying offenses

Original Post:

I’m still working on revising the Legislative Goal page, but everyday I wind up working on a post or two because of the revisions I’m making. 

Today I was gathering all the past legislation that has been proposed to expand Virginia’s Residency Restrictions and Loitering Laws since I became a volunteer advocate (the list is at the very bottom) even though I routinely share all the research with those same lawmakers but they continue to propose expansion anyway. 

Now that 2017’s HB1485 has been signed by the Governor McAuliffe and becomes law on July 1st, Delegate Dickie Bell is out touting his “big win” to news outlets, with a press release. 

·         Out-of-state sex offenders get tighter Va. Regulation, March 21, 2017
·         Governor signs Delegate Bell's House Bill 1485, March 21, 2017
·         Governor McAuliffe Signs Sex Offender Bill, March 21, 2017
·         Governor McAuliffe Signs Sex Offender Bill Patroned by Dickie Bell, March 20, 2017
·         McAuliffe signs sex-offender legislation patroned by Bell, March 20, 2017

So I’ve decided to share more details about where HB1485 came from and what Delegate Bell claimed to know and not know about it when we spoke on the phone back on December 20, 2016. 

Delegate Bell has publically claimed he had a "constituent" who came to him about HB1485. 

Well that’s not totally accurate; the “constituent” was a Virginia State Police Investigator. 

From the phone call on December 20, 2016 Delegate Bell told me the VSP Investigator’s original intent with HB1485 was to ban Registered Sex Offender's from all Virginia libraries because the Investigator told him there was an RSO that was “hanging around” the children’s section of the Bristol library. I then advised Delegate Bell that Virginia’s Loitering law does NOT include libraries, so HB1485 would do nothing to change that situation.  

I then advised Delegate Bell I opposed SB384 back in 2014 that was intended to ban RSO’s from Virginia Libraries which was a request by a Commonwealth’s Attorney in Senator Reeves' district. I advised Bell that in 2014 I opposed SB384 in its original form and in its amended forms because in the end it was a ban and that was ruled unconstitutional by the New Mexico Supreme Court. 

So Delegate Bell then told me the VSP Investigator advised him that Virginia needed to “align with Federal Code” and that HB1485 would get us there. 

I then explained to Delegate Bell that I’m well versed in Federal Code for “Sex Offenders” it’s the Adam Walsh Act 2006 also known as SORNA which does NOT have loitering or residency restriction for “Sex Offenders”. Then that there were some pending Bills in Washington for employment of RSO’s with children, but they had not become Federal law at that point. So on the second claim by the VSP Investigator on what HB1485 would do, he was wrong again, or perhaps he had lied to the Delegate or perhaps the Delegate wasn’t being truthful with me. Which option was it? I had been given  2 reasons for HB1485 that were NOT true and I had to make sure these false claims did not spread as fact in an attempt to get public support or Legislature support for this Bill and any Companion version that may pop up at session. 

Monday, March 20, 2017

Virginia State Police Allocates 173% More Hours Each Year to the VCheck Firearm Program than for RSO’s to Be Able to Register, Re-register and Update Data Changes to Avoid a Felony

Hours of operation, the ability to access the Virginia State Police is what this post will be about.
Of Virginia’s 22,588 (October 2016 count) Registered Sex Offenders 40% are incarcerated, 20% are under VA-DOC supervision and 40% are under Virginia State Police supervision. So that’s 60% that must re-register every 30, 90, 120 or 365 days each year. Plus anytime the RSO moves, changes jobs, enrolls or un-enrolls in school, buys or sells a vehicle or deletes or create san email address they must go in-person to a Virginia State Police location within either 3 days (not business days) or 30 minutes (for email and Instant Messenger) per Virginia law. 

Some RSO’s might go to their local police or sheriff’s office for VSP Registry changes but experience has taught most RSO’s that’s a risk with a possible felony punishment. Registration paperwork has been known to take forever to get from a local authority to the VSP or it has been lost all together, so most VA RSO’s go directly to the VSP. 

60% of the RSO population that utilizes the VSP locations is 13,177 people. The majority of those people must re-register 4 times per year (every 90 days) but some do so through the mail 2 or 3 of those 4 times. But then there are those data changes and in the last 10 years we’ve personally learned that averages one visit per year and yet we’ve never changed our residence or employment and most RSO’s do. 

So let’s go with a very conservative average of 2 visits to a VSP location per year for the 13,177 RSO’s. 

A VSP Trooper or VSP employee spends an average of 20 minutes with each RSO who comes in to re-register or update their data. 

That works out to be  26,354 visits per year to a VSP location by Virginia RSO’s at 20 minutes each that’s 8,784 hours in 2015 was needed to manage all the Registered Sex Offenders in Virginia. 

50 States: Juvenile Registration as Sex Offenders - Public, Private or Not at All?

The below list is outdated, please do not use it.
The revised and completely accurate list can be found at


Original Post:

No Registration for Juveniles:
  1. Alaska
  2. Connecticut
  3. Hawaii
  4. Nebraska
  5. West Virginia
  6. District of Columbia
State that have Private (Authorities Only) Registries:
  1. Arizona                          for Tier/Level 1 AND some Juveniles
  2. Arkansas                       for some Juveniles
  3. Colorado*                   for Juveniles
  4. Delaware                    for Tier/Level 1
  5. Idaho                           for Juveniles
  6. Illinois                         for Juveniles
  7. Maryland*                  for Juveniles
  8. Massachusetts            for Tier/Level 1 AND 2’s AND some Juveniles
  9. Michigan*                  for Juveniles
  10. Minnesota                   for Tier/Level 1 AND 2’s AND Juveniles
  11. Nevada*                       for Tier/Level 0 AND 1’s
  12. New Hampshire          for Tier/Level 1 AND Juveniles
  13. New Jersey                  for Tier/Level 1 AND some 2’s AND some Juveniles
  14. New York                     for Tier/Level 1 AND Juveniles
  15. North Carolina             for Juveniles
  16. Oklahoma*                    for Juveniles
  17. Pennsylvania*             for Juveniles
  18. Rhode Island                for Tier/Level 1 AND Juveniles
  19. Tennessee*                  for Juveniles
  20. Vermont                        for Juveniles until age of 18 then placed on Internet
  21. Wisconsin                     for Tier/Level 1 AND 2’s AND Juveniles
  22. Wyoming*                   for Juveniles 
State has Automatic Removal from Registry for Juveniles:
  1. New Hampshire             at age 17
  2. Idaho                                at age 21
  3. Maryland*                       at age 21
  4. Missouri                         at age 21         (for some)
  5. Oklahoma *                     at age 21
  6. Arizona                             at age 25
  7. Texas                                at 10th year OR end of jurisdiction which ever comes first
State allows a Court Petition for Removal from Registry for Juveniles:

Sunday, March 19, 2017

In the Last 9 Years the Virginia Legislature has Used the VA-DMV 4 Times to Take Away Options, Access and Offerings from Those Who are Listed on the VSP Registry

I’m still working on revising the Legislative Goal page, I hope to have it finished tomorrow. 

But as I was reorganizing my goals I came to realize just how many times the Virginia Legislature has used the VA-DMV to tighten restrictions, limit access (no online or US mail) and limit offerings for both VSP Registry Offenders AND their loved ones. PLUS get more money out of them and ONLY them because they have to return so often! 

In the last 9 years 4 different DMV related laws went into effect. 

Saturday, March 18, 2017

Farewell Legislative Goal #2, You Were Extremely Worthy but the Virginia State Police Opposed You for More than 7 Years…..So They Won, While Virginians Lost

I am redoing my Legislative Goal page this weekend. One of the changes that may be noticed on that page is Goal #2 is not what it used to be. That’s because I’ve removed it and am no longer working on it. 

But I wanted to be sure Goal #2 is documented on this site because I spent a lot of time over 8 Virginia General Assemblies trying to accomplish Goal #2 but at every turn the Virginia State Police Legislative Liaisons became a barrier, with different excuses or demands every session. 

So this Post today is a look back at 8 years of trying to get one simple and necessary reform accomplished in Virginia and the unbelievable push-back that occurred.

What is the problem or problems, what are the possible solutions, steps taken to achieve those solutions, who objected and how did they object and where are we today. Are we better off? NO we aren’t. Read on.

Mary Devoy

Original Goal #2 was, written notice of all Legal Restrictions /Regulations that all Registered Sex Offenders (RSO) must abide by in Virginia be given. 

When new "Sex Offender" laws are passed in Virginia, including restricting their movement, their employment, their housing or what information is mandated to be submitted within a specific timeframe by the Offender, they are NOT notified of the change in law, but yet are obligated to follow the new rule.

These specific laws passed by the Virginia Legislature carry a penalty of a Class 6 Felony, even if the original conviction requiring registration was a misdemeanor. These laws are not intuitive but yet RSO’s are expected not to violate them. 

When a Virginian is under DOC Probation they receive a complete list of rules that they sign to acknowledge receipt. Then if the Probationer breaks a rule, they face the legal consequences for the violation. 

But the Commonwealth makes no effort  to advise Registered Sex Offenders (RSO's) and their “Rules of the Game” change yearly when new retroactive laws are passed and if they "guess" incorrectly they face up to 5 years in prison. An extremely high cost paid for by Virginians for an arbitrary felony based on an administrative act (the VSP Registry). 

If a law (that originally required a fiscal impact) is important enough for the Virginia Legislature to pass, is it NOT equally important to inform those citizens it is intended to manage? 

States like North Carolina, Illinois & Indiana advise their RSO’s of their legal obligations at every re-registration and Illinois & Kentucky notify their RSO's of new changes in law. 

All Virginia and all Federal laws should be available in easily understandable terms not legal mumbo-jumbo.  

The first copy would be given to an RSO at upon their first registration and then an updated and complete list given each year after the General Assembly session when the new laws take effect on July 1st . 

The list would be posted on-line and available upon request including to be mailed to those RSO’s without Internet access.

Friday, March 17, 2017

Action Item for Virginia HB1485-Patroned by Delegate Dickie Bell, Ask Governor McAuliffe to Veto it OR to Amend it, TODAY!

Update 4:50PM 03/17:

In the last hour LIS has updated HB1485, Governor McAuliffe signed it into law yesterday. It was only posted in LIS 2-3 days ago that the Bill was headed to the Governor. So much for public comment or amendments to be considered in Virginia. It’s an anti-Sex Offender Bill? Sign it, sign it, sign it! Don’t ask questions, don’t consider the collateral consequences, they’re JUST Sex Offenders.

The Virginia State Police will be applying this new law retroactively upon RSO’s whose convictions go back as far as 2000 and the VSP will NOT be notifying them of their new restrictions ahead of time. 


Original Post:

HB1485 adds any person convicted of an offense under the laws of any foreign country or any political subdivision thereof, or the United States or any political subdivision thereof to:
·         §§ 18.2-370.2 (Loitering) within 100 feet:
§      A primary, secondary or high school, if the conviction is on or after July 1, 2000
§      A child day center if the conviction is on or after July 1, 2006
§      A locality operated playground, athletic field or facility, or gymnasium, if the conviction is on or after July 1, 2008 “for the purpose of having any contact whatsoever with children that are not in his custody”
·         §§ 18.2-370.3 (Residency) within 500 feet:
§      A primary, secondary or high school, if the conviction is on or after July 1, 2006 and if the Offender is 3 or more years older than the victim
§      A child day center (as defined in § 63.2-100 ), if the conviction is on or after July 1, 2006 and if the Offender is 3 or more years older than the victim
§      The boundary line of any place he knows is a public park, if the conviction is on or after July 1, 2008 and if the Offender is 3 or more years older than the victim  when such park:
                                                      (i) Is owned and operated by a county, city or town
                                                      (ii) Shares a boundary line with a primary, secondary, or high school
                                                      (iii) Is regularly used for school activities
                        * The residence is allowed if the school, daycare or park is established subsequent to his conviction
·         §§ 18.2-370.4 (Employment or Volunteering)
§      A primary, secondary or high school, if the conviction is on or after July 1, 2006 and if the Offender is 3 or more years older than the victim
§      A child day center if the conviction is on or after July 1, 2006 and if the Offender is 3 or more years older than the victim 

And a grandfather clause was added for residences established prior to July 1, 2017. 

The Virginia State Police will be applying HB1485 retroactively to Registered Sex Offenders who are already listed on the VSP Registry for an out-of-state, Federal, Military, Foreign or Tribal conviction will now be obligated to abide by these 3 changes in VA Code. 

But the VSP refuses to notify those affected RSO’s of the change in law that will apply to them as of July 1, 2017 which has a felony punishment and limits their housing options. 

This means any RSO who has been picking up or dropping off their child on the corner of school property or waits for them in the parking lot during soccer, band or cheerleader practice today will be unknowingly committing a felony as of July 1, 2017. Yes, the section for playground, athletic field or gymnasium says "for the purpose of having contact...." but we all know an arrest and an investigation will occur if anyone makes a complaint and that means bail, hiring an attorney and possible loss of employment and the burden to prove what contact was or wasn't being made falls on the Offender, not the State!
HB1485 will also mean any RSO who moves to a new apartment or townhome or decides to buy a house after July 1, 2017 needs to know that it can not be within 500ft of a daycare or school property but will have no idea until their VSP Trooper or Compliance Officer comes to their newly registered address to confirm the change and then is told their new home is illegal. 

The Unjust, Irrational, and Unconstitutional Consequences of Pedophilia Panic By Jacob Sullum

A MUST Read!!!!!!! –Mary Devoy

The Unjust, Irrational, and Unconstitutional Consequences of Pedophilia Panic
The fear and disgust triggered by this subject help explain why laws dealing with sex offenses involving minors frequently lead to bizarre results. 

By Jacob Sullum March 15, 2017

"Sounds like you enjoy sex with kids," a reader tweeted at me after seeing a blog post I wrote about former Subway pitchman Jared Fogle. It was 2015, and Fogle had just signed a plea agreement in which he admitted to looking at child pornography and having sex with two 16-year-old prostitutes. "You also look like [a] pervert," the reader added. 

That's the sort of response you can expect if you write about the broad category known as "sex offenders" and suggest that not all of them are the same or that some of them are punished too severely. In this case, I had noted that the decision to prosecute Fogle under federal law, which had been justified by factors that had little or nothing to do with the gravity of his offenses, had a dramatic impact on the penalty he was likely to receive. 

Monday, March 6, 2017

Verizon is Eliminating Their Email Service and “Migrating” Those Accounts to AOL, for Virginia’s RSO’s That Don’t Know or Act Fast Enough This Could Amount to a Felony

In less than 10 hours a VA RSO who checks this site regularly and who email’s me learned their Verizon email will be transferring to AOL. They advised me that they have NOT heard one word about this switch from Verizon. Now they are keeping an eye on their account and looking for email’s about the switch so they can try to comply with VA law.

Their email address may not change or stop working at first but at some point down the line AOL is going to want their name in the email addresses of their users to say AOL, not Verizon.

Original Post:
Just 30 minutes ago I walked into my living room and heard the end of a Richmond NBC12 news story that not only caught my attention but immediately made me consider the possible arbitrary felonies that may follow soon in Virginia via the Virginia State Police (VSP). 

The news story (which is NOT posted on NBC12 as of right now) is that Verizon is discontinuing its email service and those accounts will be “migrated” to AOL accounts. It seems this has been news for a week now, but tonight’s story was the very first I had heard of it. 

After a Google search I found an article with some details here

So what’s the issue? 

Per § 9.1-903. Virginia’s 22,000+ Registered Sex Offenders (RSO) have ONLY 30 minutes to register in-person (there is no phone or electronic system) ANY change (additions or deletions) with their email. And as a side note the Virginia State Police Barracks are not open evenings, weekends or holidays. 

So per tonight’s news I’ve learned Verizon is going to delete existing email addresses and it sounds as though new AOL addresses may be created all behind the scenes without any involvement of the person who owned the Verizon account.  

Now I check email daily but there are MANY people who do not. They might check it weekly or it could be monthly. But for RSO’s in Virginia if an email address has been deleted by Verizon and created by AOL without any action (at a VSP location) by the person who is attached to the account they could be facing a new felony. First an investigation, then charges and an arrest, then bail (if they can come up with it), possible loss of employment, hiring an attorney, and then a court date. All because Verizon is eliminating email service and they’ve handed it over to AOL. 

A Throwaway Line in a Magazine from 1986 is the Basis for the last 22 years of Sex Offender Legislation, Restrictions and Requirements in America

03/18/17- Some very good editorials written after the below NY Times article:
·         Radley Balko: The big lie about sex offender, March 9, 2017
·         Questionable Statistic Pervades High Court Sex Offender Cases, March 8, 2017
·         The Supreme Court’s Sex-Offender Jurisprudence Is Based on a Lie, March 7, 2017
        The Supreme Court believes most sex offenders will keep committing sex crimes. The data suggests otherwise.
·         How the Supreme Court Spread a False Statistic About Sex Offenders, March 6, 2017

The below was emailed to every Virginia Legislator this morning. - Mary

Dear Virginia Delegates and Senators, 

Last week the U.S. Supreme Court heard the oral arguments for Packingham v. North Carolina. 

I have been sharing and posting many opinion pieces and articles on the case but this NY Times piece today is so very important that I’ve decided to share it with all of you. 


Dubious Data Belies Supreme Court’s Stance on Repeat Sex Offenders, March 6, 2017
By Adam Liptak

Last week at the Supreme Court, a lawyer made what seemed like an unremarkable point about registered sex offenders. 

“This court has recognized that they have a high rate of recidivism and are very likely to do this again,” said the lawyer, Robert C. Montgomery, who was defending a North Carolina statute that bars sex offenders from using Facebook, Twitter and other social media services. 

The Supreme Court has indeed said the risk that sex offenders will commit new crimes is “frightening and high.” That phrase, in a 2003 decision upholding Alaska’s sex offender registration law, has been exceptionally influential. It has appeared in more than 100 lower-court opinions, and it has helped justify laws that effectively banish registered sex offenders from many aspects of everyday life. 

But there is vanishingly little evidence for the Supreme Court’s assertion that convicted sex offenders commit new offenses at very high rates. The story behind the notion, it turns out, starts with a throwaway line in a glossy magazine. 

Justice Anthony M. Kennedy’s majority opinion in the 2003 case, Smith v. Doe, cited one of his own earlier opinions for support, and that opinion did include a startling statistic. “The rate of recidivism of untreated offenders has been estimated to be as high as 80 percent,” Justice Kennedy wrote in the earlier case, McKune v. Lile. 

He cited what seemed to be a good source for the statistic: “A Practitioner’s Guide to Treating the Incarcerated Male Sex Offender,” published in 1988 by the Justice Department. 

The guide, a compendium of papers from outside experts, is 231 pages long, and it contains lots of statistics on sex offender recidivism rates. Many of them were in the single digits, some a little higher. Only one source claimed an 80 percent rate, and the guide itself said that number might be exaggerated.

The source of the 80 percent figure was a 1986 article in Psychology Today, a magazine written for a general audience. The article was about a counseling program run by the authors, and they made a statement that could be good for business. “Most untreated sex offenders released from prison go on to commit more offenses — indeed, as many as 80 percent do,” the article said, without evidence or elaboration. 

That’s it. The basis for much of American jurisprudence and legislation about sex offenders was rooted in an offhand and unsupported statement in a mass-market magazine, not a peer-reviewed journal. 

“Unfortunately,” Melissa Hamilton wrote in a new article in The Boston College Law Review, “the Supreme Court’s scientifically dubious guidance on the actual risk of recidivism that sex offenders pose has been unquestionably repeated by almost all other lower courts that have upheld the public safety need for targeted sex offender restrictions.”