Connecticut Department of Public Safety v. Doe, 538 U.S. 1 (2003), was a United States Supreme Court case in which the court held that due process does not require the opportunity to prove a fact that is not material to a state's statutory scheme. Mere injury to reputation does not implicate a liberty interest.Syllabus of . Miller, Erin. "Let the burden fit the crime: Extending proportionality review to sex offenders." Yale LJ 123 (2013): 1607.

Background Among other things, Connecticut's "Megan's Law" requires people convicted of sexual offenses to register with the Department of Public Safety (DPS) upon their release into the community, and requires DPS to post a sex offender registry containing registrants' names, addresses, photographs, and descriptions on a website and to make the registry available to the public in certain state offices.

The website contained the following disclaimer:

Doe, a convicted sex offender who was subject to the law, filed a 42 U.S.C. § 1983 action on behalf of himself and similarly situated sex offenders, claiming that the law violated, among other things, the Fourteenth Amendment's Due Process Clause. The federal District Court granted Doe summary judgment, certified a class of people subject to the law, and permanently enjoined the law's public disclosure provisions. The Second Circuit Court of Appeals affirmed, concluding that such disclosure both deprived registered sex offenders of a "liberty interest," and violated the Due Process Clause because officials did not afford registrants a pre-deprivation hearing to determine whether they are likely to be "currently dangerous."

The Supreme Court granted certiorari.

Opinion of the Court The Supreme Court issued an opinion on March 5, 2003. The court held that due process does not require the opportunity to prove a fact that is not material to the State's statutory scheme. Injury to reputation in itself, even if defamatory, does not constitute deprivation of liberty. The Second Circuit's judgment was reversed.

References

Further reading

External links

Brief for the Unisted States as Amicus Curiae Supporting Petitioner ACLU Brief for the Respondents in Connecticut Dept. of Public Safety v. Doe (10/2/2002) Amicus brief in Connecticut Dept. of Public Safety v. Doe - Urging the court to find that governmental dissemination of truthful information about a person does not trigger "due process" requirements.