Amicus Curiae Brief of the A.D.T.C. Legal Subcommittee A.A. v. Codey, Docket No.: 59,521

George Riley, Horace Glenn, James J. Krivacska, David Tuytjens, Jeffrey Parker, & Joel Durmer

INTRODUCTION

     Recently, the members of the Legal Subcommittee of the Inmate Resident Committee (IRC) at the Adult Diagnostic & Treatment Center (A.D.T.C.) in Avenel, New Jersey, filed a motion with the New Jersey Supreme Court seeking leave to file an amicus curiae, or friend of the court brief, in the case now before the court, A.A. et al. v. State of New Jersey, et al, (Docket No.: 59,521).  This case concerns the constitutionality of the amendment to the New Jersey Constitution passed by the citizens of New Jersey in 2000, known as Paragraph 12, which strips those who have been convicted of a sexual offense of a broad swathe of constitutional protections.  The case also concerns the constitutionality of the "Sex Offender Internet Registry" enacted into law by the Legislature in 2002.

     The A.D.T.C. is the New Jersey Department of Corrections (DOC) facility designated to receive and treat those who have been convicted of a sexual offense, and have been found to suffer from a mental condition which is characterized by a pattern of compulsive and repetitive behaviors.  The IRC is an administration sanctioned body, whose members are elected by the ADTC resident population to represent the interests of the residents to the administration.  The Legal Subcommittee of the IRC, also sanctioned by the administration, is charged with advocating for and acting to protect the rights and interests of those incarcerated at the ADTC.

     The vast majority of residents receiving treatment at the ADTC will be returning to their communities, and face a difficult adjustment and period of reintegration into their communities.  Successful navigation of that reintegration is vital to these residents transferring the skills they have learned in therapy at the ADTC to their life on the outside, and is critical to ensuring the safety of the communities in which they will live.  The enactments being challenged by the case now before the State Supreme Court, fail to protect communities, risk destabilizing the lives of those it targets, and are based on false perceptions and persistent myths about the risks posed by those convicted of a sex offense and released into the community.

     Contrary to widespread beliefs about sex offending recidivism, the rate at which those convicted of a sex offense and treated at the ADTC sexually reoffend upon release is under 10%, based on published data from empirical studies and NJ DOC's own recidivism statistics.

     The enclosed amicus curiae brief is intended to provide the New Jersey Supreme Court with the most reliable, up-to-date and accurate information relevant to this important public policy debate, and to educate the court about the risk of harm these enactments pose to those it targets, harm which ultimately will make our communities less, not more safe.

─────────────────────────────────────

 
A.A, AB., AC., AD., (by M.M., his natural parent),
A.e., A.F., and AG. (all fictitious initials), individually
and on behalf of all others similarly situated,

Plaintiffs,

 v.

STATE OF NEW JERSEY; JON S. CORZINE, in his
official capacity as Governor, State of New Jersey;
ZULIMA FARBER, in her official capacity as Attorney
General, State of New Jersey; and JOSEPH R.
FUENTES, in his official capacity as Superintendent of
the New Jersey State Police,

Defendants.
















SUPREME COURT OF NEW JERSEY

DOCKET NO: 59,521

App. Div. Docket No.:
A-2153-04T1

Civil Action

Sat Below:

Hon. Edwin H. Stern, P.J.A.D.
Hon. Robert A Fall, J.A.D.
Hon. Clarkson S. Fisher, Jr., J.A.D.

─────────────────────────────────────

 

Amicus Curiae Brief Submitted By The
A.D.T.C. Inmate Resident Committee Legal Subcommittee

  On the Brief:
George Riley, Chairman, IRC
  Legal Subcommittee, Pro se

Horace Glenn, Chairman, Inmate
  Resident Committee, Pro se
James J. Krivacska, Pro se
David Tuytjens, Pro se
Jeffrey Parker, Pro se
Joel Durmer, Pro se

Adult Diagnostic &
Treatment Center
8 Production Way
Avenel, NJ 07001

TABLE OF CONTENTS

Table of Authorities
Table of Appendices
Preliminary Statement
Point I Low Rates Of Sex Offending Recidivism By Those Convicted Of Sex Crimes Means The Sex Offender Internet Registry Act And Constitutional Amendment Passed In 2000 Authorizing Such Laws Are Not Reasonably Related To A Legitimate Government Interest
 
A. Assuming Public Safety Is The Interest Served,
These Enactments Are Not Rationally Related to
Those Interests

1. Sex Offending Recidivism of ICSOs in New Jersey

 
B. The Class of "Sex Offenders" Targeted by the Internet
Registry Act and Paragraph 121s Overbroad and
Not Rationally Drawn
 
C. The Internet Registry and Paragraph 12 do Not
Advance a legitimate Government Interest
 
D. An ICSO's Fundamental Right to Life and Liberty
 
E. The Internet Registry Act and Paragraph 12 Do Not
Advance Legitimate State Interests As They Reduce,
Not Enhance Safety
Conclusion
Footnotes

TABLE OF AUTHORITIES

STATE CASES

A.A.. et al. v. Codey. et al., 384 N.J.Super. 481 (2006)

1, 2, 4

Caviglia v. Royal Tours, 178 ~ 460 (2004) 6
Greenberg v. Kimmelman, 99 ~ 552 (1985) 4
Planned Parenthood of Cent. NJ v. Farmer, 165 ~ 609 (2000) 6, 7

FEDERAL CASES

McKune v. Lile, 536 ~ 24 (2002) 2, 3
Northern Securities v. United States, 193~ 197 (1904) 1
Smith v. Doe, 358 ~ 84 (2003) 2

STATE STATUTES

N.J.S. .& 2C:4 7 -9 2
N.J.S. .& 2C: 7 -12 2
N.J.S. .& 30:4-27 .24 3

OTHER AUTHORITIES

Adams, G. (April 18, 2006). Cops: Sex offenders' killer found names on state site. Chicago Sun-Times 5
Clarke, M.J. (2006, Feb). "Two registered Sex Offenders Murdered in Bellingham, WA" Prison Legal News, p. 40 5
Division of State Police. (2004). New Jersey Uniform Crime Report - 2004. Trenton, NJ: Department of Law and Public Safety 1, 4
Finkel, N.J. (2006). Moral Monsters and Patriot Acts: Rights and Duties in the Worst of Times.
Psychology. Public Policy and Law, llm, 242-277
1, 2, 4, 6
Hanson, R.K. (2002). Recidivism and age: Follow-up data from 4,673 sex offenders. Journal of Interpersonal Violence, 1I{1Ql, 1 046-62 3
Hanson, R.K., & Morton-Bourgon, K.E. (2005). The characteristics of persistent sex offenders: A meta-analysis of recidivism studies. Journal of Consulting & Clinical Psychology, 11, 1154-63 3
Hanson, R.K., Bussiere, M. (1998). Predicting Relapse: A meta-analysis of Sexual Offender Recidivism Studies. Journal of Consulting & Clinical Psychology, Q2, 348 3
Langan, P. A, & Levin, D.J. (June, 2002). Recidivism of Prisoners Released in 1994. Washington, D.C.: US Dept. of Justice, Bureau of Justice Statistics (NCJ 193427) 3
Langan, P. A, Schmitt, E. L., & Durose, M.R. (November 2003). Recidivism of Sex Offenders Released from Prison in 1994. Washington, DC.: US Dept. of Justice, Bureau of Justice Statistics (NCJ 198281) 3, 4, 5, 6
Marshall, W.L., Anderson, D., & Champagne, F. (1997). Self-esteem and its relationship to sexual offending. Psychology. Crime & Law, 3, 161-86 6
Marshall, W.L., Ward, T., Mann, R.E., Moulden, Y.M., Serran, G. & Marshall, L.E. (2005). Working positively with sexual offenders: Maximizing the effectiveness of treatment. Journal of Interpersonal Violence, 20(9), 1096-1114 6
Moulden, H.M., & Marshall, W.L. (2005). Hope in the treatment of sexual offenders: The potential application of hope theory. Psychology, Crime & Law, 11(3), 329-342 7
New Jersey Dept. of Corrections. (November 5,2001). Release Outcome 1994 Through 1997: Sex Offenders Follow-up. Trenton, NJ: Author 2
Sager, W. (November 10, 2000). Report-1994 Releasee Recidivism Study. Avenel, NJ: Adult Diagnostic & Treatment Center 2
Sager, W. (October 10, 2001). Report -1995 Releasee Recidivism Study. Avenel, NJ: Adult Diagnostic & Treatment Center 2
Ward, T., & Hudson, S.M. (1996). Relapse Prevention: A critical analysis. Sexual Abuse: A Journal of Research & Treatment, 8(3), 177-200 7
Ward, T., & Stewart, C.A. (2003). The treatment of sex offenders: Risk Management and good lives. Professional Psychology: Research and Practice, 34(4), 353-360 7
Wollert, R (2006). Low Base Rates Limit Expert Certainty When Current Actuarials Are Used to Identify Sexually Violent Predators: An Application of Bayes's Theorem. Psychology. Public Policy & Law,12(1), 56-85 3
Wollert, R. (2001). An analysis of the Argument that clinicians under-predict sexual violence in civil commitment cases. Behavioral Sciences & the Law, 19, 171-184 6
Zgoba, K. M., Sager, W.R., & Witt, P.H. (2003). Evaluation of New Jersey's Sex Offender Treatment Program at the Adult Diagnostic & Treatment Center: Preliminary Results. The Journal of Psychiatry & Law, 31, 133-164 2, 3, 5

[Back to Table of Contents]

TABLE OF APPENDICES

APPENDIX A Calculation of Risk Posed by Released ICSO

APPENDIX B Percent of Released Prisoners Rearrested for Same Offense For Which They Had Been Incarcerated Prior to Release

APPENDIX C Percent of Released Prisoners Rearrested for Any Offense By Offense For Which They Had Been Incarcerated Prior to Release

[Back to Table of Contents]

PRELIMINARY STATEMENT

Great cases, like hard cases, make bad law.  For great cases are called great, not by reason of their real importance in shaping the law of the future, but because of some accident of immediate overwhelming. interest which appeals to the feelings and distorts the judgment.  These immediate interests exercise a kind of hydraulic pressure which makes what previously was clear seem doubtful, and before which even well settled principles of law will bend. Northern Securities v. United States, 193 U.S. 197,400-401 (1904) (Dissent of Justice Holmes)

        In the wake of the tragic cases of the rape and murder of innocent children, the "hydraulic pressure" placed upon politicians to act has resulted in enactments ostensibly intended to protect children, absent real debate or an unbiased or nuanced evaluation and critical analysis of available normative and empirical evidence1.  The result is bad law.  Exhibiting a stubborn refusal to discern variability in the heterogeneous group of individuals convicted of a sex offense (hereinafter "ICSO"2), legislators legitimize, through legislation, the demonization, stigmatization and ostracization of what is portrayed as an "undifferentiated group, invariant in their desires and behaviors"3.  The Appellate Division decision noted as much while quoting the sponsor of the bill proposing the Constitutional Amendment.

What we are looking to do with this constitutional amendment is to see that, once and for all, the public's right to have knowledge about sexual predators is actually provided ...
A.A., et al. v. Codey, et al., 384 N.J. Super. 481,494, n7 (2006). (Emphasis added)

        Thus does this legislator lump the 19 children under the age of 10 who were arrested for a sexual offense in 20044 In with the 20 year old heterosexual male who has a consensual sexual relationship with a nearly 16 year old girl, in with the 40 year old fixated pedophile who has  sodomized over a dozen prepubescent boys over a 20  year period.  To support such legislation, politicians

... frequently claim that these moral monsters have the highest recidivism rates, recidivate more frequently, cannot control their impulses, and cannot change even though a now large body of empirical findings has shown these claims to be myth.5 (emphasis added)

        So this Court is confronted with the awesome responsibility imposed on it by the State Constitution.  It may abdicate its obligation, as so many other courts have, or it may dispassionately evaluate the validity of the assumptions,  perceptions, motivations and prejudices behind these enactments and execute its duty as a check against the excesses of the other branches of government6.  The determination it reaches may not be popular, but in its hands rest the vestiges of liberty and the right to pursue safety and happiness to which even a citizen convicted of a sex offense having paid his or her debt to society is entitled.

POINT I

Low Rates of Sex Offending Recidivism by
Those Convicted of Sex Crimes Means the Sex
Offender Internet Registry Act and Constitutional
Amendment Passed in 2000 Authorizing
 Such Laws are Not Rationally Related to
a Legitimate Government Interest

        In the Appellate decision below, the court observed that

... [i]f a legislative classification does not burden a  fundamental right or target a suspect class, it will be upheld so long as it bears a rational relation to a legitimate government interest.  A.A. v. Coder, supra, at  889 (internal citations omitted).

        While protection of the public from criminal activity is undisputedly a "legitimate government interest," the degree to which the law under consideration, N.H.S. 2C:7-12 to 19 (hereinafter "Internet Registry Act") and the Constitutional Amendment to Article IV, Section VII, paragraph 12 of the New Jersey Constitution (hereinafter Paragraph 12) is rationally related to that interest is considerably more tenuous, if not totally absent, than advocates of these measures allege and the decision of the lower court suggests.  Moreover, the likelihood that the Internet Registry Act and Paragraph 12 will increase the risk to the public obviates the legitimacy of the governmental interest asserted.

A.     ASSUMING PUBLIC SAFETY IS THE INTEREST SERVED, THESE ENACTMENTS ARE NOT RATIONALLY RELATED TO THOSE INTERESTS

        In support of its legal holdings, the Court below, while acknowledging that the United States Supreme Court did not resolve an equal protection claim in the challenge to the Alaska Internet Registry, nevertheless quoted from a portion of that decision.

"Alaska could conclude [based on recent studies] that a conviction for a sex offense provides evidence of a substantial risk of recidivism, Smith v. Doe, 358 U.S. 84, 103 (2003)." A.A. v. Codey, supra, at 490.

        In support of its conclusion that the Internet Registry Act and Paragraph 12 have a rational basis, the Appellate Court noted

... the United States Supreme Court quoted authority relating to the hIgh rate of recidivism among sex offenders and the possibility of reoffending at long intervals thereby demonstrating a rational basis for treating them differently from other offenders. Id. at 490.

    Concluding that Paragraph 12 was justified by the "risk of recidivism by the more dangerous sex offenders," Id. at 491, the Appellate Court noted that Congress and the states had passed registration laws based on the theory of high recidivism.  It even quoted the U.S. Supreme Court, which had commented that

"[s]ex offenders are a serious threat in this nation" and "[w]hen convicted sex offenders reenter society, they are much more likely than any other type of offender to be rearrested for a new rape or sexual; assault." Id. at 491, citing McKune v. Lile, 536 U.S. 24, 32-33 (2002).

        Without further analysis, and based solely on these prior Congressional findings and U.S. Supreme Court commentary7, the Appellate Court concluded that Paragraph 12 serves a legitimate State interest in public safety  and does not irrationally target an unpopular group. Id. at 491.  If, however, the underlying premise of high rates of  recidivism is proven to be false, that rational relationship  now fails.  Unfortunately, the lower court erred because it  failed to rely on the only recidivism evidence relevant to a law targeting ICSOs in New Jersey; reoffense rates of NJ  ICSOs.  In fact, such rates are among the lowest of all classes of offenders8.  (See Appendices B & C, infra).

1.       Sex Offending Recidivism of ICSOs in New Jersey

        In the mid- to late-90s, New Jersey Legislators and policy makers suffered from a dearth of State specific data to ground the various measures passed to protect children from sex crimes.  That excuse is no longer available.  Data from various sources, as described below, establish a long-term recidivism rate of less than 13% for  those convicted of a sex crime in New Jersey.  For example, in 2000 and 2001 the New Jersey Department of Corrections (NJDOC), pursuant to legislative mandate N.J.S.  2C:47-9, compiled 5 year recidivism data for ADTC sentenced inmates who were released into the community in 1994 and 1995.  These two studies reported rates of 6%9 and 6.5%10, respectively.  Also released was a study of the 10 year recidivism rate (3,8%) for those released from ADTC in 1990.  Additionally, ICSOs released between 1994-97 were followed for 3 years and had among the lowest reconviction rates for any crime (26%) of all prison releases (especially A.D.T.C. releasees: 18% reconvictionrate for any offence)11.

        This data is consistent with a formal study12 tracking recidivism for all releasees from ADTC and other state prisons in 1990-91 with a sex offense conviction.  Zgoba found that only 8.6% of those released from the ADTC reoffended by committing another sex offense after 10 years, compared to 12.7% of those released from State prisons13.  In fact, there has never been a published New Jersey sex offense recidivism rate higher than that 12.7% rate.

        Consistent with these findings, Bureau of Justice Statistics (BJS) found a 5.3% rate of sex offense recidivism for released ICSOs over a three year period14 compared to 1.3% for released offenders incarcerated for non-sex crimes15, 16.  It is commonly reported that ICSOs are four times more likely to commit another sex offense (5.3%) than other offenders (1.3%)17.  Given the low percentages involved, the "four times more likely" characterization is a bit disingenuous, and unduly alarming.  By that logic since those convicted of homicide are four times more likely to commit another homicide than a sex offender (1.2%18 versus .3%19), perhaps an Internet Registry for murders is warranted, an observation that factors into the similarly situated component of the equal protection analysis.

        In fact, as far as recidivism goes, with the exception of homicide, sex offenders are the least likely to recommit the same offense for which they were incarcerated after release. See Appendix B. And, again second to homicide, sex offenders are the least likely to commit any offense after release. See Appendix C.

        Finally, a pair of meta-analytic studies20 found the sex offending recidivism rate over a 5-6 year period after release to be between 13.4%21 and 13.7%22.

        While individually published studies have revealed a wider range of higher and lower recidivism rates, the advantage of meta-analytic studies is to smooth out that variability to yield an estimated recidivism rate that better approximates the actual rate in the community23, 24.

        Crucially nearly all studies on which the Legislature relied in the 1990s were based on selected samples of sex offending individuals in an attempt to estimate the true recidivism rate in the entire sex offending population.  The BJS, NJDOC and Zgoba, et al. studies, however, don't sample the population of ICSOs; rather they include the entire population of ICSOs.  Thus, the recidivism rates are not estimates of the sex offending recidivism rates; they are the actual recidivism rates for the whole population in New Jersey based on official records25.  Consequently, no more accurate data than that provided in the Zgoba, et al study or by the NJDOC or the BJS is possible.  It is indisputable that the actual rate of sex offending recidivism in New Jersey as measured by official law enforcement records and for at least a 10 year period is under 13% (under 9% for those treated at the ADTC.)26

        Importantly, during the 1990s the follow-up period used by these studies civil commitment under the Sexually Violent Predators Act (N.J.S. 30:4-27.24 et seq) was not yet available.  Since then, approximately 350 individuals are now being held in the Special Treatment Unit as "Sexually Violent Predators" because they pose the highest risk of reoffending.  By removing such individuals from the pool of potential recidivists, the 12.7% New Jersey recidivist rate must correspondingly fall as well.  Thus, the current actual risk posed by sex offending releases will continue to decrease each year as a greater percentage of the highest risk offenders are civilly committed and the population ages.

        These statistics belie the rationale taken for granted in A.A. v. Codey.  Except for those convicted of murder, those convicted of sex offenses are the least likely to recommit the same offense for which they were incarcerated (See Appendix B), and have the lowest rate of recidivism of all released offenders (See Appendix C).  Such statistics beg the question, "If ICSOs reoffend less frequently than other released ex-cons, do these enactments not 'discriminate arbitrarily between persons who are similarly situated'?" Greenberg v. Kimmelman, 99 N.J. 552, 577 (1985).

        Nor can the court ignore the inequity of classifying all ICSOs together.  The State does distinguish a subset of sex offenders, "Sexually Violent Predators" (SVPAs), with high rates of recidivism, and confines them for treatment making them irrelevant under the Internet Registry Act or Paragraph 12.  Yet, in defending these enactments, the State pretends the high risk group rather than being securely confined in the Special Treatment Units (STUs) is lurking on our streets and playgrounds, and then defines the whole class of individuals (from the 9,365 juveniles arrested for a sex offense27, to the 73% of offenders who were related to or close friends of their victim28 to the 6.7% of offenders who took stranger victims29), as if they shared the same high risk propensities.

        The problem with the State's classification is that the group to which the legislation was targeted, no longer exists, at least to roam free on the streets.  This myopia is, according to Finkel, to be expected because

when fearful and vindictive passions conjoin, research findings in the psychology of emotion or cognition [ ] generally show a narrowing (and clouding) of what one sees and a widening of what one fails to see.30

        Unfortunately, this Court remains the only check against this narrowing.

 

B.     THE CLASS OF "SEX OFFENDERS" TARGETED BY THE INTERNET REGISTRY ACT AND PARA. GRAPH 12 IS OVERBROAD AND NOT RATION. ALLY DRAWN

        The problem posed by Paragraph 12 is that the "status" of ICSO never changes.  In 2004, 19 children under the age of 10 were arrested for a sex offense (a total of 472 between 1990 and 2004).  If convicted, under Paragraph 12 the State may, for the rest of their lives, designate them as a "sex offender" on the Internet31.  A man may have committed a sex offense thirty years ago as a teenager, but as far as the state is concerned, he is still a sex offender.  But, in reality, he is not.  The law makes no distinction between those who suffer from a mental disorder or disability that predisposes them to be sexually aroused to minor children and a normal heterosexual adult who makes an error in judgment and engages in consensual sexual relations with a nearly 16 year old teenager32.

        There is no mechanism for becoming an ex-sex offender.  That makes it a trait, not related to continuing conduct.  It is immutable and unchangeable.  An individual who continues to offend, or who continues to be under the supervision of the state may perhaps deserve the title "sex offender."  But once he has returned to living a law abiding life, given the low recidivism rates, it is not appropriate to continue to describe him as a "sex offender," without more than his previous criminal history.

 

C.     THE INTERNET REGISTRY AND PARAGRAPH 12 DO NOT ADVANCE A LEGITIMATE GOVERNMENT INTEREST

        We have challenged the assumptions regarding recidivism underlying the Internet Registry.  The Appellate Division concluded that the Internet Registry passed constitutional muster without the application of Paragraph 12.  If public notification via the Internet is already constitutionally permissible without Paragraph 12, and if the type of sex offense that the Internet Registry is intended to prevent is among the rarest of all criminal offenses, save murder, and if Paragraph 12 lumps low and high risk offenders together even while the provision is justified solely by reference to the high risk offenders, and if the state has already incapacitated the highest risk offenders under the SVP, there is no real rationale left to justify Paragraph 12; except, that is, animus toward a politically unpopular group.

        First, there is no rational reason to believe that the Internet Registry Act will prevent the most common forms of child sexual assault; familial abuse and abuse by a boy/girlfriend or close friend (72.3% of all sex crimes against children33).  The Internet Registry is primarily intended to prevent stranger abuse, which makes up 6.7% of abuse victims34.  Even adding acquaintance abuse, only an additional 19.7% of child sexual abuse victimizations are accounted for.  Taking the highest reported sex offending recidivism rate (12.7%35), for every 1,000 released ICSOs over a 10 year period, 33 can be expected to commit another sex offense ((19.6% + 6.7%) x 12.7% x 1000)36.  From 1990-99, an estimated 1,890 ICSOs37 were released, of which 62 may be expected to reoffend [33 x (1,890/1000)].

        Another approach to analyzing risk of assaults by an ICSO, is to estimate the likelihood that an individual arrested for a sexual offense will be an ICSO or that an act
of child sexual assault will be committed by a released ICSO. For every 1,000 arrests for sexual assault, approximately 4 of the arrestees will be non-juvenile, non- intrafamilial ICSOs and approximately 2 will be the type of offender the Internet Registry is designed to warn about38.

        For every 1,000 sexual assaults in New Jersey, an estimated 1 will be committed by a non-juvenile, non-intrafamilial ICSO, and less than one, or .6, will be perpetrated by the type of offender the Internet Registry is designed to warn about39.  Thus, a child is over 1,000 times more likely to be sexually assaulted by someone other than an ICSO for whom the Internet Registry is designed.

        Finally, compared to the Annual Crime Index in NJ (28.1 per 1,000 inhabitants for all crime; 3.6 per 1,000 inhabitants for violent crime)40, the ICSO recidivist's sexual assault index is an estimated .007 per 1,000 inhabitants41, 42.

        Because the Internet Registry and Paragraph 12 give no more protection to the citizens of the State than is currently available, its only purpose is to stigmatize ICSOs,
strip them publicly of constitutional rights, the effect of which is to communicate to society that ICSOs are less than full citizens of America, if not of the human race43.  When the State publicly and needlessly strips a class of its citizen of constitutional protection, it should not be surprised when the State's citizens interpret that act as giving them license to harass and treat inhumanely those the State has cast out from under its protective umbrella.

 

D.     AN ICSO'S FUNDAMENTAL RIGHT TO LIFE AND LIBERTY

        Efforts to make society safer inevitably also lead to restrictions on the freedom of some innocents.  In the case of the Internet Registry, not only are the liberties of innocents being affected (family, friends, and employers of ICSOs), so too is their safety.  As documented by the public defender's office, the more than 100 acts of harassment and violence against ICSOs and their families and friends are a testament to the power of the State's label "sexual predator."  It is only a matter of time before, like Washington and Maine, New Jersey becomes the site of a murder of an ICSO posted on the Internet Registry.

        The State cannot choose to minimally increase protection to one group of citizens at the expense of substantially increasing the risk of harm to another group44. Under
the State Constitution, analysis of equal protection claims requires applying

a flexible balancing test that weighs the nature of the right, the extent of the governmental restriction of the right, and whether the restriction is in the public interest. Caviglia v. Royal Tours, 178 N.J. 460, 479 (2004).

        The New Jersey Constitution provides:

All persons are by nature free and independent, and have certain natural and unalienable rights, among which are those of enjoying and defending life and liberty, of acquiring, possessing and protecting property, and of pursuing and obtaining safety and happiness.
Article I, paragraph 1. (Emphasis added).

        The Internet Registry, because of its indiscriminate, broad swathe of disclosure, deprives ICSOs and their families of "enjoying and defending life and liberty" and of "pursuing and obtaining safety and happiness," as attested to by the more than 100 incidents noted above.  Thus, these State constitutional rights are severely restricted by these enactments.  The low probability of the Internet Registry providing any real protection to the public, infra at Point I.A.2. and 3, and the low rate of ICSO recidivism, infra at Point I.A.1, when weighed against the harm to the ICSO and their families, is insufficient to survive an equal protection challenge.

        The weighing of the rights of the individual versus that of society must be grounded not on public perception or misperception of risk but on the actual risk posed.  In Planned Parenthood of Cent. NJ v. Farmer, 165 N.J. 609 (2000), the State proposed numerous claims of valid State interests facilitated by a Parental Notification Act.  However, the Court carefully examined the facts behind the asserted State interests and found those facts lacked support in the professional literature. Id. at 640.  So, too, here must the Court look beyond the bald assertions of the State and rely upon the sound scientifically derived data summarized herein.

 

E.     THE INTERNET REGISTRY ACT AND PARAGRAPH 12 DO NOT ADVANCE LEGITIMATE STATE INTERESTS AS THEY REDUCE, NOT ENHANCE SAFETY

        Fear of the unknown can be powerful and debilitating, provoking a desire to punish moral transgressors or "moral monsters"45.  Unfortunately, the sense of safety the Registry confers is illusory, and probably false.  With approximately 87% of sex offenses by released convicts committed by those with no sex offending history (and therefore not listed on the Registry)46, and with 86% to 90% of those incarcerated for a sex offense serving time for their first sex offense47, 48, that sense of security may be particularly misleading.

        The Court should also be mindful of the risk that the Internet Registry and Paragraph 12 will decrease public safety.  The relationship between an ICSO and his community is interactive, if not somewhat symbiotic.  The risk posed by ICSOs is not divorced from their standing and role in the communities in which they live, or their mental health, and the court should not ignore the stigmatization that an ICSO and his/her family or friends will suffer from an Internet Registry posting49.  The attempt by society to meet its needs for safety is likely to paradoxically result in increased risk.  At ADTC, for example, ICSOs learn to accept themselves as valued and valuable members of the broader humanity, to not define themselves by the worst thing they ever did.  This does not mean diminishing or minimizing the harm they've caused.  Just the opposite.  It means accepting responsibility for that harm and committing, as part of accepting their intrinsic self-worth and humanity, to refrain from harming others again.

        It is a well-accepted phenomena in psychology that "a stigmatized individual will come to view himself based upon what he believes other people think he is" which is more likely to promote continued criminal behavior50.  If an individual comes to see himself as an incorrigible "sexual offender," it becomes easy to abandon what must seem like pointless attempts at changing behavior51.  Conversely, enhancement of feelings of self-worth, self-efficacy, agency, and connectedness to others, facilitates transition to and maintenance of an offense free life- style52.

... when society's reaction to deviants is to stigmatize, segregate and exclude, such persons are left with limited opportunity for achieving self-respect and affiliation in the mainstream but are welcomed among subcultural groups of similarly stigmatized outcasts. Hence the vicious cycle of persistent offending.53

        Self-efficacy is related to a decrease in sex offending recidivism54. And helping ICSOs to replace their sex offending mentality with "an alternative and pro-social identity" is pivotal to moving individuals into crime-free lifestyles55 because "desistance [from crime] may be best facilitated when the desisting person's change in behavior is recognized by others and reflected back to him in a 'delabeling process'"56.  Significantly increasing the stress ICSOs experience may overwhelm learned coping strategies, placing the ICSO at greater risk for relapse57.  The stress associated with losing a job that is the only source of income one has for himself and his family, of being evicted from an apartment with no place to go especially if his family is evicted with him of being subjected to verbal and physical abuse and witnessing family and friends enduring the same; all of these create enormous levels of stress.

        State action that leads to diminution of the mental health and stability of any portion of its citizenry is an insult which can't be constitutionally sanctioned, especially in the absence of a measurable benefit to the community.  When the State creates, perpetuates or institutionalizes stigma, promoting a diminished sense of acceptance and belonging for a class of its citizens, it enters constitutionally suspect territory.  The concern here is not solely the safety of our children versus the mental health of sex offenders.  The fact is that to the extent that the mental health of sex offenders is impaired, the risk to children increases.  When a statutory enactment "'may ... cause serious emotional harm ...' and 'perpetuate[] a family crisis, characterized by ... rejection'" the weighing analysis may favor voiding the statute. Planned Parenthood, supra, at 640.

        The ideal, of course, would be a society which recognizes the potentially dangerous proclivities of some ICSOs and, while remaining on guard for signs of their re-emergence, accepts and supports the ICSO to become integrated into the community and live a healthful, law-abiding and safe life.  If that ideal is to be ever achieved, the State must recognize its responsibilities to all its citizens and not needlessly, irrationally, and gratuitously stigmatize one subgroup.

        Nor should this court ignore the toxic effect of the law on the exercise of innocent individuals' rights and liberties (ICSOs' parents, children, friends, and employers), and of the message the law conveys: a curse not only on those who have committed heinous crimes but on any who dare affirm their humanity and who risk aid and support for their reintegration into society.

        The Internet Registry and Paragraph 12 have become an instrument for the destruction of personal lives, not the protection of innocent ones.  Partisan emotions drown out voices of reason, and regardless of whether this Court's voice can be projected loud enough to breakthrough; it should not defensively join the prevailing chorus of unreason.  Rather it should exercise the constitutional purpose for which it was created as a check against the exuberant excesses of the other branches, as a check against Madison's "tyranny of the majority."

 

CONCLUSION

        Based on the foregoing, Amicus Curiae pray that this Court will hear the matter proposed and find for the Plaintiffs.

By:

George Riley, Pro se

By:

Horace Glenn, Pro se

By:

James J. Krivacska, Pro se

By:

David Tuytjens, Pro se

By:

Jeffrey Parker, Pro se

By:

Joel Durmer, Pro se

By:

Anthony Marchitto, Pro se

DATE: June 20, 2006

[Back to Table of Contents]

APPENDIX A

Total Arrests for Sexual Assault and Rape 1990-99A1

                               
  1990 1991 1992 1993 1994 1995 1996 1997 1998 1999   TOTALS   Ave./Yr  
                               
Sex Asslt 2,130 2,384 2,458 2,449 2,325 2,161 2,080 2,300 2,399 2,146   22,832   2,283  
Rapes 1,290 1,244 1,319 1,222 1,095 1,023 948 827 773 663   10,404   1,040  
                               
TOTALS 3,420 3,628 3,777 3,671 3,420 3,184 3,028 3,127 3,172 2,809   33,236   3,324  
                               

Crime Index Statistics 1990-99A2

 
  1990 1991 1992 1993 1994 1995 1996 1997 1998 1999   TOTALS   Ave./Yr  
                               
Total Rapes 2,308 2,261 2,399 2,214 1,964 1,924 1,972 1,730 1,623 1,412   19,807   1,981  
Total Crime 421,034 421,663 394,406 378,302 368,155 373,706 346,094 326,912 296,638     3,604,382   360,438  
                               
Total Arrests 84,741 85,108 79,608 76,921 76,296 77,389 73,657 70,876 63,558 57,215   745,369   74,537  
                               

 

Crime Index Statistics For Crimes/Arrests 1990-99

Total Annual Reported Arrests, all crimesA3 745,369
Total Annual Reported Crimes, all crimesA3 3,604,382
Ratio of Reported Crimes to Reported Arrests (3,604,382 / 745,369) 4.84:1
Total Annual Reported Arrests for Sexual AssaultA4 2,283
   
Average Annual Estimated Sexual Assaults
        [2,283 x 4.84]A5
11,050

 

Average Number of ICSOs released by the State Yearly

Year A.D.T.C. Other State
Prisons
TOTAL ICSO
Releasees
Source
         
1990-91 163 236 399 ZgobaA6
1994 112 31 143 NJDOCA7
1995 128 50 178 NJDOC
1996 131 73 204 NJDOC
1997 136 72 208 NJDOC
         
6 Yr Total 670 462 1,132  
Ave. per/yr 112 77 189  
         

 

 

Predicted Recidivism of Released ICSOs Targeted by the Internet Registry

   
Estimated ICSOs released 1990-1999 1,890.0
   
Highest ICSO Rec'd RateA8 12.7%
   
Non-intrafamilial Abuse RateA9 65.0%
   
Percentage of non-Juvenile ICSOSA10 80.0%
   
Non-intrafamilial, Non-Juvenile ICSOs
      Total Percentage of Non-intrafamilial, Non-Juvenile ICSOs [65% x 80%]
52%
   
Number of expected non-juvenile, non-intrafamilial ICSO recidivists Over 10 years
      [1,890 x 12.7% x 52%]
125
   
Number of expected non-juvenile, non-intrafamilial ICSO recidivists per 1,000
      arrests for sexual offenses during the 1990s
      [(125/33,240) x 1,000]
3.8
   
Number of Reported Sexual Assaults Attributable to expected non-juvenile,
      non-intrafamilial ICSOs per 1,000 reported assaults, Per Year
      [{(128/10) / 11,050} x 1,000]
1.2
   
Annual Index per 1,000 inhabitants under the age of 15 suffering sexual assaults
      attributable to expected non-juvenile, non-extrafamilial ICSOs.
      [{(128/10 / 8,414,350A11 x 21.4%A12)} X 1,000]
.007
   
   
Stranger/Acquaintance ICSOs
      Stranger                                                             6.7%
      Acquaintance/other                                            19.6%
      Total Percentage of ICSOs Targeted by InternetA13
26.3%
   
Number of expected ICSO recidivists targeted by the Internet Registry, over 10 years
      [1,890 x 12.7% x 26.3%]
63
   
Number of ICSO recidivists targeted by the Internet Registry expected to be
      arrested, per 1,000 arrests/year, during the 1990s
      [(63/33,240) x 1,000]
1.9
   
Number of Reported Sexual Assaults Attributable to ICSO recidivists targeted by the
      Internet Registry per 1,000 reported assaults, Per Year
      [{(63/ 10) / 11 ,050} x 1,000]
.6
   
Annual Index per 1,000 inhabitants, under the age of 15 suffering sexual assaults
      attributable to ICSO recidivists targeted by the Internet Registry
      [{(63/10) / (8,414,35011 x 21.4%12)} X 1,000]
.004
   

[Back to Table of Contents]

APPENDIX B

Percent of Released Prisoners Rearrested for Same Offense
For Which They Had Been Incarcerated Prior to Release
B1
 

Offense

Percent
   
Homicide 1.2%
Rape 2.5%
Motor Vehicle Theft 11.5%
Robbery 13.4%
Fraud 19.0%
Assault 22.0%
Burglary 23.4%
Public Disorder 31.2%
Larceny / Theft 33.9%
Drug Offenses 41.2%

[Back to Table of Contents]

APPENDIX C

Percent of Released Prisoners Rearrested for Any Offense
By Offense For Which They Had Been Incarcerated Prior to Release
C1
 

Offense

Percent
   
Homicide 40.7%
Sexual Assault 41.4%
Rape 46.0%
Other Violent Crime 51.7%
Arson 57.7%
Kidnapping 59.4%
Public Disorder 62.2%
Assault 65.1%
Fraud 66.3%
Drug Offense 66.7%
Robbery 70.2%
Other Property; Offenses 71.1%
Burglary 74.0%
Larceny / Theft 74.6%
Stolen Property 77.4%
Motor Vehicle Theft 78.8%

[Back to Table of Contents]

Footnotes

1 Finkel, N.J. (2006). Moral Monsters and Patriot Acts: Rights and Duties in the Worst of Times. Psychology, Public Policy and Law, 12(2), 242-277, at 250, 255.  [Back]

 2 As argued later in this brief, the label 'sex offender' imputes to the individual and his or her entire persona and character, the nature of his or her crime. To label individuals by their offense is to define who they are, for all time, by the worse mistake they have ever made, and denies to them any chance at redemption and vindication. Thus throughout this brief, the label 'sex offender' is avoided where possible, substituted with this acronym to demonstrate that the individuals toward whom these laws are directed are more than the offense which they have committed.  [Back]

3 Id., at 254.  [Back]

4 Division of State Police. (2004). New Jersey Uniform Crime Report 2004.Trenton, NJ: Department of Law and Public Safety, at 44. (hereinafter "NJUCR')  [Back]

5 Finkel, at 254 (list of nine research and meta-analytic studies, some of which will be detailed below, omitted).  [Back]

6 The normal political process by which a group of citizens may petition its elected representatives to protect its interests is largely closed to ICSOs for practical political reasons. To defend, or even acknowledge, the rights of ICSOs is political suicide. For example, Julie Roginsky, spokesperson for Assemblyman Albio Sires, during the Democratic Primary Election for the unexpired House of Representatives term of Robert Menendez, repeatedly attacked Sires' opponent, Assemblyman Joseph Vas, as sympathetic to "convicted child molesters' because he had written a letter seeking leniency for a friend who had been convicted of sexual contact with a 14 year old girl. (Zackary Fink, correspondent. (June 6, 2006; 8:15 PM). New Jersey Network Primary '06 Coverage. NJN News, Monclair, NJ).  [Back]

7 The finding in Smith v. Doe, supra, that sex offenders are highly likely to reoffend was even, at the time, "at odds with the recidivism findings from empirical investigations." Finkel, at 258, cites omitted.  [Back]

8 Much of which research post-dates the research relied upon in Smith  v. Doe, supra, and McKune v. Lile, supra.  [Back]

9 Sager, W. (November 10, 2000). Report 1994 Releasee Recidivism Study, Avenel, NJ: Adult Diagnostic & Treatment Center.  [Back]

10 Sager, W. (October 10, 2001). Report 1995 Releasee Recidivism Study, Avenel, NJ: Adult Diagnostic & Treatment Center.  [Back]

11 New Jersey Dept. of Corrections. (November 5, 2001). Release Outcome 1994  Through 1997: Sex Offenders Released at Maximum Sentence, A.D.T.C. Releases vs. General Population Sex Offenders: A Three Year Follow-Up. Trenton, NJ: Author.  [Back]

12 Zgoba, K. M., Sager, W.R., & Witt, P.H. (2003). Evaluation of New Jersey's Sex Offender Treatment Program at the Adult Diagnostic & Treatment Center: Preliminary Results. The Journal of Psychiatry & Law, 31, 133-164.  [Back]

13 Id. at 154.  [Back]

14 Langan, P. A., Schmitt, E. L., & Durose, M.R. (November 2003). Recidivism of Sex Offenders Released from Prison in 1994. Washington, DC.: US Dept. of Justice, Bureau of Justice Statistics (NCJ 198281). (hereinafter "Sex Offender Releasees Study")  [Back]

15 Id., at 24.  [Back]

16 Although the rate was lower for such releasees, from a public safety perspective, they had a much greater impact. Of the 3,845 new sex crimes committed by the 272,111 releasees the DOJ study tracked, 3,328 were committed by those previously incarcerated for non-sex crimes. In other words, individuals with prior convictions for a sex crime, were responsible for only about 13% of the sex crimes committed by a prison releasee. Another way to look at it is that an individual is more than six times more likely to be sexually assaulted by someone who has a criminal history for other than sex crimes, than by someone with a prior sex crime conviction.  [Back]

17 This was the source of Justice Kennedy's much cited observation that sex offenders were "much more likely than any other type of offender to be rearrested for a new rape or sexual assault.' McKune v. Lile, supra., at 32-33.  [Back]

18 Langan, P. A., & Levin, D.J. (June, 2002). Recidivism of Prisoners Released in 1994. Washington, D.C.: US Dept. of Justice, Bureau of Justice Statistics (NCJ 193427), p. 1 (hereinafter "Prisoner Releasees Study") at 9.  [Back]

19 Sex Offender Releasees Study at 34.  [Back]

20 Meta-analysis "The process or technique of synthesizing research results by using various statistical methods to retrieve, select, and combine results from previous separate but related studies." Excerpted from The American Heritage Dictionary of the English Language, Third Edition 1996 by Houghton Mifflin Company.  [Back]

21 Hanson, R.K., Bussiere, M. (1998). Predicting Relapse: A meta-analysis of Sexual Offender Recidivism Studies. Journal of Consulting & Clinical Psychology, 66, 348.  [Back]

22 Hanson, R.K., & Morton-Bourgon, K.E. (2005). The characteristics of persistent sex offenders: A meta-analysis of recidivism studies. Journal of Consulting & Clinical Psychology, 73, 1154-63.  [Back]

23 Most studies yielding higher recidivism rates were based on small samples drawn from high risk populations since the New Jersey Constitutional Amendment makes no distinction between higher and lower risk populations, the overall or general sex offending recidivism rate is most appropriate for this analysis.  [Back]

24 The 1998 meta-analysis was based on data from 61 different studies, with a total of 28,972 sex offenders with sex offenses convictions. The 2005 meta-analytic study was based on data from 82 different studies, with a total of 19,267 subjects with sex offense convictions. These two studies provide among the most reliable recidivism rates available in the literature today.  [Back]

25 The U.S. Dept. of Justice study tracked all released sex offenders from state prison in 15 States including New Jersey.  [Back]

26 Of course, some additional recidivists would be caught if the 10 year follow-up period was extended. However, the incremental recidivism is likely to be small. Recidivism drops with age, even for sex offenders (about 3-4% per year) from about 27% for 18-24 year olds, to 3% for those 60 and over. Hanson, R.K. (2002). Recidivism and age: Follow-up data from 4,673 sex offenders. Journal of Interpersonal Violence, 17(10), 1046-62. Moreover, there is no sound scientific methodology or empirical data upon which an extrapolation may be based, making any long term recidivism predictions nothing more than speculation. Wollert, R (2006). Low Base Rates Limit Expert Certainty When Current Actuarials Are Used to Identify Sexually Violent Predators: An Application of Bayes's Theorem. Psychology. Public Policy & Law, 12(1), 56-85.  [Back]

27 NJUCR -1990-2004, Section 111 Total Arrests by Age.  [Back]

28 Sex Offender Releasees Study, at 36.  [Back]

29 Id.  [Back]

30 Finkel, at 268.  [Back]

31 The fact the current Internet Registry excludes incest, Tier I and juvenile offenders is irrelevant. Paragraph 12 strips all those convicted of a sex offense of their due process rights, whether the illegal act was committed at age 10 or age 40, regardless of Tier status, and regardless of whether the offense was incest related or a statutory rape offense.  [Back]

32 Age of consent laws are, of necessity, arbitrary, as evidenced by their variability across states. But to extend the law's arbitrary nature such that any who violate its proscriptions by even a day, are automatically consigned to a lifetime designation as a sexual deviant / sex offender; perverts the meaning of the term. The quality of being sexually deviant, a mental disorder, must rest on psychomedical foundations, not an accident of birthdate that triggers imposition of a label predicated upon whether a sexual relationship took place a minute before or a minute after midnight.  [Back]

33 Sex Offender Releasees Study, at 36.  [Back]

34 Id.  [Back]

35 Zgoba, et al. at 154.  [Back]

36 8.5 per 1,000 released ICSOs if only stranger assaults are considered. (6.7% x 12.7% x 1000).  [Back]

37 See Appendix A, infra.  [Back]

38 See Appendix A for the detailed calculations used.  [Back]

39 Ibid.  [Back]

40 NJ UCR 2004, Id., at 12.  [Back]

41 See calculations presented in Appendix A  [Back]

42 By comparison, according to the World Almanac & Book of Facts, (2005). NY: World Almanac Books, at 75, 80, the infant mortality rate in the U.S. is 3.5 per 1,000, and the motor vehicle death rate is .2 per 1,000.  [Back]

43 The enmity which society holds against ICSOs reached its nadir in the last year with at least four registered ICSOs killed based on information published about them on Internet Web sites including two in Oregon, (Clarke, M.J. (2006, Feb). 'Two registered Sex Offenders Murdered in Bellingham, WA' Prison Legal News, p. 40.) and Maine, (Adams, G. (April 18, 2006). Cops: Sex offenders' killer found names on state site. Chicago Sun-Times, at http://www.suntimes.com/output/news/ces-nws-sex18.html).  [Back]

44 Nor does the Internet Registry address the fact that it, like community notification, only changes who the potential victim of a "predatory"offender is. An individual determined to find a child victim will not be deterred by either the Internet Registry or community notification or zoning restrictions. He will simply look for his victim where he is anonymous. All the Internet Registry does is change who the victim will likely be. If all the Registry does is increase the safety of one community by increasing the risk in another, it has failed in its stated purpose.  [Back]

45 Finkel, at 268.  [Back]

46 Sex Offender Releasees Study, p. 24.  [Back]

47 Sex Offender Releasees Study, p. 11.  [Back]

48 Wollert, R. (2001). An analysis of the Argument that clinicians under-predict sexual violence in civil commitment cases. Behavioral Sciences & the Law, 19, 171-184, at 176.  [Back]

49 Finkel, at 259.  [Back]

50 Maruna, S., LeBel, T.P., Mitchell, N., & Naples, M. (2004). Pygmalion in the reintegration process: Desistance from crime through the looking glass. Psychology, Crime & Law, 10(3), 271-81, at 378.  [Back]

51 Marshall, W.L., Anderson, D., & Champagne, F. (1997). Self-esteem and its relationship to sexual offending. Psychology. Crime & Law, 3, 161-86, at 52.  [Back]

52 Marshall, W.L., Ward, T., Mann, R.E., Moulden, Y.M., Serran, G. & Marshall, L.E. (2005). Working positively with sexual offenders: Maximizing the effectiveness of treatment. Journal of Interpersonal Violence, 20(9), 1096-1114, at 1105-06.  [Back]

53 Maruna, at 273.  [Back]

54 Moulden, H.M., & Marshall, W.L. (2005). Hope in the treatment of sexual offenders: The potential application of hope theory. Psvchology, Crime & Law, 11(3), 329-342, at 333.  [Back]

55 Ward, T., & Stewart, CA. (2003). The treatment of sex offenders: Risk Management and good lives. Professional Psychology: Research and Practice, 34(4), 353-360, at 355.  [Back]

56 Maruna, at 274.  [Back]

57 Ward, T., & Hudson, S.M. (1996). Relapse Prevention: A critical analysis. Sexual Abuse: A Journal of Research & Treatment, 8(3), 177- 200, at177.  [Back]

A1 NJUCR -1990-1999, at 42-44, see fn4, infra  [Back]

A2 NJUCR -1990-1999 at 12, 42-44, see fn4, infra  [Back]

A3 For the seven major crimes tracked by the UCR: Murder, Rape, Robbery, Agg. Assault, Burglary, Larceny/Theft, Motor Vehicle Theft  [Back]

A4 NJUCR -1990-1999, at 42-44.  [Back]

A5 The NJUCR does not report the number of reported sexual assaults (other than rape), just the number of arrests, thus necessitating this estimation.  [Back]

A6 See fn12, infra  [Back]

A7 See fn11, infra  [Back]

A8 Zgoba, See fn12, infra: Note this is an inflated rate because it assumes a constant rate of recidivism each year.  [Back]

A9 Sex Offender Releasees Study, at 36, See fn14, infra  [Back]

A10 NJUCR 1990-99 [26,573(non-juvenile) /33,236 (Total) = 80%].  [Back]

A11 New Jersey Population, 2000 Census: Source, The World Almanac, ld. at 623.  [Back]

A12 Percentage of U.S. Population under age 15: Source, The World Almanac, ld. at 627.  [Back]

A13 Sex Offender Releasees Study, at 36, see fn14, infra: Excludes assaults committed on family members, boy/girlfriends, ex-boy/girlfriends, and friend/ex-friends as these types of assaults would not be expected to be prevented by the Internet Registry as the sexual assaulter is already well known to the victim.  [Back]

B1 Prisoner Releasee Study, Table 10, at 9.  [Back]

C1 Prisoner Releasee Study, Table 9, at 8.  [Back]

[Back to Table of Contents]

 

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