New York Court of Appeals

The People v. Superintendent, Woodbourne Correctional Facility

June 15, 2023

Summary

The Court of Appeals held that retroactive application of the SARA school-grounds condition does not violate the Ex Post Facto Clause. Although the condition imposes restraints resembling punishment and may prolong incarceration for offenders unable to find compliant housing, petitioner failed to provide sufficient evidence that prolonged incarceration is a common effect across the regulated class or that the condition is so punitive as to overcome the Legislature's civil, child-protection purpose.