H.R. v. N.J. State Parole Board

Based on a prior conviction, H.R. was subject to New Jersey’s Sex Offender Monitoring Act (SOMA), and thus was required to be monitored by GPS upon release from custody. He sued, claiming that the monitoring was an unreasonable search under Article I, Paragraph 7 of the New Jersey Constitution. The Parole Board responded that the search fell within the state’s “special needs” exception to the warrant requirement, as the probable-cause requirement is impracticable. In weighing the competing needs of the government and the individual, the Court ruled that the special needs exception applied and the search was reasonable.