John Doe, Sex Offender Registry Board No. 22460 v. Sex Offender Registry Board.

CourtMassachusetts Appeals Court
DecidedJune 5, 2026
Docket25-P-0368
StatusUnpublished

This text of John Doe, Sex Offender Registry Board No. 22460 v. Sex Offender Registry Board. (John Doe, Sex Offender Registry Board No. 22460 v. Sex Offender Registry Board.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Doe, Sex Offender Registry Board No. 22460 v. Sex Offender Registry Board., (Mass. Ct. App. 2026).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

25-P-368

JOHN DOE, SEX OFFENDER REGISTRY BOARD NO. 22460

vs.

SEX OFFENDER REGISTRY BOARD.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiff, John Doe, appeals from a Superior Court

judgment affirming his reclassification by the Sex Offender

Registry Board (SORB or board) as a level two sex offender. On

appeal, Doe raises two overarching issues. First, he argues

that the board's decision was arbitrary and capricious and not

supported by substantial evidence because the hearing examiner

failed to make detailed findings of Doe's risk of reoffense and

degree of dangerousness. Second, Doe argues that his Superior

Court counsel was ineffective for failing to challenge the hearing examiner's application of factors 10, 24, 33, and 38.1

We affirm.

Discussion. 1. Standard of review. "We review a judge's

consideration of an agency decision de novo." Doe, Sex Offender

Registry Bd. No. 523391 v. Sex Offender Registry Bd., 95 Mass.

App. Ct. 85, 89 (2019). "To determine the validity of an

agency's decision, the reviewing court must determine whether

the decision is supported by substantial evidence." Doe, Sex

Offender Registry Bd. No. 10216 v. Sex Offender Registry Bd.,

447 Mass. 779, 787 (2006). Substantial evidence is "such

evidence as a reasonable mind might accept as adequate to

support a conclusion." G. L. c. 30A, § 1 (6). "[W]e give due

weight to the experience, technical competence, and specialized

knowledge of the agency" (citation omitted). Doe, Sex Offender

Registry Bd. No. 528042 v. Sex Offender Registry Bd., 496 Mass.

437, 441 (2025) (Doe No. 528042). A hearing examiner also has

discretion to consider which regulatory factors are applicable

in each case and how much weight to give to each factor. Id.

See Doe, Sex Offender Registry Bd. No. 136652 v. Sex Offender

1 We refer to SORB's classification factors by number, or name and number, it being understood that each of them appears in the corresponding subpart of 803 Code Mass. Regs. § 1.33 (2016). SORB's regulations were updated in 2025, but the 2016 version of the regulations were in effect at the time of the hearing examiner's decision in this case and therefore govern our analysis.

2 Registry Bd., 81 Mass. App. Ct. 639, 651 (2012). "Accordingly,

our review does not turn on whether, faced with the same set of

facts, we would have drawn the same conclusion as an agency or

local board, but only whether a contrary conclusion is not

merely a possible but a necessary inference" (quotation,

citation, alteration omitted). Doe, Sex Offender Registry Bd.

No. 68549 v. Sex Offender Registry Bd., 470 Mass. 102, 110

(2014).

2. Doe's level two classification. Doe argues his level

two classification was arbitrary and capricious, with the main

thrust of the argument being that the hearing examiner used a

"checklist approach." Perfunctory, checklist risk-

classification decisions are, of course, incompatible with the

reasoned analysis required of a SORB classification. See Doe,

Sex Offender Registry Bd. No. 11204 v. Sex Offender Registry

Bd., 97 Mass. App. Ct. 564, 575-576 (2020) (Doe No. 11204).

Furthermore, hearing examiners are required "to make explicit

[their] findings regarding each of . . . three elements, [risk

of reoffense, degree of dangerousness, and Internet

publication,] and to make clear that each determination is

supported by clear and convincing evidence." Doe, Sex Offender

Registry Bd. No. 496501 v. Sex Offender Registry Bd., 482 Mass.

643, 657 (2019) (Doe No. 496501). Here, the hearing examiner's

3 analysis was detailed and specific to Doe's personal

circumstances and far from a "tally sheet of aggravating and

mitigating factors." Doe No. 11204, supra. Rather than a

simple determination that "the former outweighed the latter,"

id. at 576, the hearing examiner noted which factors contributed

to his analysis for each element and considered the relevant

research.

Doe also argues that the hearing examiner improperly

considered factors 10, 11, 12, and 15 as part of his assessment

of Doe's degree of dangerousness. Factor 10 relates to contact

with the criminal justice system; factor 11 to violence

unrelated to sex assaults; factor 12 to behavior while

incarcerated or civilly committed; and factor 15 to hostility

toward women. In evaluating an offender's degree of

dangerousness, "a hearing examiner must consider 'the severity

and extent of the harm the offender would present to the public

in the event of reoffense.'" Doe No. 496501, 482 Mass. at 659,

quoting 803 Code Mass. Regs. § 1.20(2)(b) (2016). This

consideration must include "the nature and type of offense the

offender would be likely to commit if he or she reoffended."

Doe No. 496501, supra. Doe argues that, because the above

factors do not bear directly on the "nature and type" of

4 potential reoffense, the hearing examiner's consideration of

these factors was erroneous. We disagree.

First, we note that the regulation specifies that the

presence of each of the above factors correlates to an increased

degree of dangerousness. See 803 Code Mass. Regs. § 1.33(10)-

(12), (15). Second, contrary to Doe's position, the holding in

Doe No. 496501 does not require that every factor relate to the

nature and type of a potential reoffense in determining the

degree of dangerousness. Rather, the holding provides that the

level of dangerousness a hearing examiner finds in each case

should logically relate to the level of harm an offender is

capable of causing. See Doe No. 496501, 482 Mass. at 659-660

(risk of reoffense relating only to noncontact offenses, where

victim not put in fear of bodily harm, unlikely to pose moderate

degree of dangerousness). Here, Doe was convicted of two counts

of aggravated rape, in violation of G. L. c. 265, § 22 (a),

stemming from an incident in which he orally and vaginally raped

the victim and threatened to kill her with a gun. Given Doe's

history of sexual violence, the hearing examiner's decision was

neither arbitrary and capricious nor unsupported by substantial

evidence.

The remainder of Doe's appellate argument amounts to a

challenge to the regulatory scheme itself, rather than any

5 particular failing of the hearing examiner. For example, Doe

takes issue with the fact that the various risk levels are not

defined in the relevant statutory and regulatory scheme. He did

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John Doe, Sex Offender Registry Board No. 22460 v. Sex Offender Registry Board., Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-doe-sex-offender-registry-board-no-22460-v-sex-offender-registry-massappct-2026.