John Doe, Sex Offender Registry Board No. 527835 v. Sex Offender Registry Board.

CourtMassachusetts Appeals Court
DecidedSeptember 19, 2025
Docket24-P-0188
StatusUnpublished

This text of John Doe, Sex Offender Registry Board No. 527835 v. Sex Offender Registry Board. (John Doe, Sex Offender Registry Board No. 527835 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. 527835 v. Sex Offender Registry Board., (Mass. Ct. App. 2025).

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

24-P-188

JOHN DOE, SEX OFFENDER REGISTRY BOARD NO. 527835

vs.

SEX OFFENDER REGISTRY BOARD.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The Sex Offender Registry Board (SORB) appeals from a

Superior Court judgment vacating SORB's classification of the

plaintiff, John Doe,1 as a level two offender.2 We agree with

the Superior Court judge that it was reasonable for the hearing

examiner to conclude that the victims' hearsay statements were

substantially reliable. Concluding that the examiner did not

assume the role of an expert when she wrote that "[t]he facts

and factors described . . . suggest a significant interest and

1 A pseudonym.

2Doe also filed a cross appeal seeking to reverse so much of the judgment that rejected his hearsay-related challenge. drive to sexually touch children, a sexual deviance," we

reverse.

1. Standard of review. "[A] decision of SORB 'may only be

set aside if the court determines that the decision is

unsupported by substantial evidence or is arbitrary or

capricious, an abuse of discretion, or not in accordance with

law.'" Doe, Sex Offender Registry Bd. No. 22188 v. Sex Offender

Registry Bd., 101 Mass. App. Ct. 797, 801 (2022), quoting Doe,

Sex Offender Registry Bd. No. 6969 v. Sex Offender Registry Bd.,

99 Mass. App. Ct. 533, 537 (2021). We review the Superior Court

judge's decision de novo. See Doe, Sex Offender Registry Bd.

No. 22164 v. Sex Offender Registry Bd., 103 Mass. App. Ct. 431,

433 (2023).

2. Role of the examiner. In her decision, the examiner

wrote, "I note that the Board recognizes that the strongest

predictors of sexual recidivism for all sex offenders are

variables related to social deviance and antisocial orientation

(803 CMR 1.30).[3] The facts and factors described above all

suggest a significant interest and drive to sexually touch

children, a sexual deviance." Doe argues that the hearing

3 As the Superior Court judge pointed out, the examiner plainly intended to cite 803 Code Mass. Regs. § 1.33 (2016), not § 1.30.

2 examiner assumed the role of an expert through her discussion of

sexual deviance. We disagree.

The term "sexual deviance" could be a code word for a

paraphilia, such as pedophilia, or it could refer simply to

sexual acts forbidden by law or society. Absent compelling

reason to believe otherwise, we expect that a SORB examiner used

the term in the same sense as used in the SORB regulations. The

term first appears in the preamble of 803 Code Mass. Regs.

§ 1.33 (2016),4 which states that "the strongest predictors of

sexual recidivism for all sex offenders are variables related to

antisocial orientation and sexual deviance. (Cortoni, 2010;

Hanson and Morton-Bourgon, 2004; Prescott 2006)."

This regulation cites Dr. R. Karl Hanson's study, Hanson

and Morton-Bourgon, Predictors of Sexual Recidivism: An Updated

Meta-Analysis (Public Works & Government Services Canada 2004)

(Hanson study), which states, "Although all sexual offending is

socially deviant, not all offenders have an enduring interest in

sexual acts that are illegal (e.g., children, rape) or highly

unusual (e.g., fetishism, auto-erotic asphyxia). Sexual

recidivism increases when such deviant interests are present, as

4 "Title 803 Code Mass. Regs. §§ 1.00 was recently amended, effective April 25, 2025. We refer to the version of the regulations in effect at the time of the hearing examiner's decision." Doe, Sex Offender Registry Bd. No. 528042 v. Sex Offender Registry Bd., 496 Mass. 437, 440 n.3 (2025).

3 indicated by self-report, offence history, or specialized

testing." Accordingly, the Hanson study uses the term sexual

deviance to refer to criminal or forbidden behavior and

interests, not to an underlying mental health diagnosis.

The first SORB factor, mental abnormality, supports this

distinction as the factor recognizes that sexual deviance may or

may not be associated with mental abnormality. See 803 Code

Mass. Regs. § 1.33(1)(a) ("The presence of a statutorily defined

mental abnormality specifically related to sexual deviance is

significantly associated with an increased risk of reoffense").

Indeed, the examiner here did not apply factor 1, suggesting

that she did not see the defendant's sexual deviance as related

to a mental abnormality.

The term next appears in factor 3, adult offender with a

child victim, which states, "Offenders who target prepubescent

children, generally younger than 13 years old, are more likely

to have a deviant sexual interest." 803 Code Mass. Regs.

§ 1.33(3)(a).5 Again, the regulations equate sexual deviance

with forbidden sexual acts, not necessarily the product of a

mental abnormality.

The term also appears in factors 4, 20, and 36. Factor 4,

age at first offense, states, "Age at first offense is an

5 The examiner applied full weight to factor 3.

4 important variable related to risk of reoffense and degree of

sexual deviance. Offenders who manifest an early onset and

persistence of deviant sexual interests or behaviors are at a

higher risk to reoffend sexually." 803 Code Mass. Regs.

§ 1.33(4)(a). Factor 20, diverse sexual behavior, states,

"Diverse sexual behavior may reflect sexual preoccupation,

elevated sex drive, or sexual deviance." 803 Code Mass. Regs.

§ 1.33(20)(a). Finally, factor 36, online offending behavior,

regarding child pornography states, "Evidence of sexual deviance

may demonstrate an increase in risk to commit contact sex

offenses." 803 Code Mass. Regs. § 1.33(36)(a)(1). This factor

further explains as follows:

"Useful indicators of sexual deviance include, but are not limited to: evidence of actively searching for images of prepubescent children; collecting larger amounts of prepubescent pornography relative to adolescent or adult pornography; collecting larger amounts of child pornography relative to adult pornography; sorting and organizing files versus random downloading; and primarily focusing on child pornography depicting boys or a higher boy to girl ratio in a collection."

803 Code Mass. Regs. § 1.33(36)(a)(1). In every usage in the

SORB regulations, "sexual deviance" refers to forbidden sexual

acts, not to acts that are the product of a mental abnormality.

In light of this, there is no reason to believe that the

examiner found sub silentio that Doe suffered from a mental

abnormality. The purpose of the regulatory scheme is for an

examiner to determine how likely an offender is to commit

5 further criminal sexual acts and the degree of dangerousness,

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JOHN DOE, SEX OFFENDER REGISTRY BOARD NO. 22188 v. SEX OFFENDER REGISTRY BOARD.
101 Mass. App. Ct. 797 (Massachusetts Appeals Court, 2022)

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