Supreme Court of Pennsylvania · 2014

In the Interest of J.B.

107 A.3d 1 (Pa. 2014)

Holding

Held that SORNA's lifetime registration requirements violate juvenile offenders' due process rights by employing an irrebuttable presumption that all juvenile sex offenders "pose a high risk of committing additional sexual offenses": that presumption is not universally true — the court credited research including a 63-study meta-analysis (11,200 youth) finding ~7% juvenile sexual recidivism, indistinguishable from non-sexual delinquents — and individualized risk assessment provides a reasonable alternative means of identifying the minority who are high-risk. Grounded in Pennsylvania's fundamental right to reputation (Art. I, §§ 1, 11).

Precedent health-check

Caution · 153 citing

Some later courts have distinguished or questioned it — read before relying.

Treatment last confirmed July 18, 2026. Case-wide subsequent treatment; human-set. Not specific to any one passage.

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Claims relevant to this case

Juveniles adjudicated for sexual offenses sexually reoffend at low rates — pooled official rates of roughly 3–10% over about five years, indistinguishable from the sexual-offense rates of other delinquent youth — while their general (nonsexual) reoffending is several times higher, and individual prediction of juvenile sexual recidivism has only modest accuracy.
Evidence: HighConsensus: Established Certified· juvenile offending / recidivism