The People v. Superintendent, Woodbourne Correctional Facility
The New York Court of Appeals addressed whether the Sexual Assault Reform Act's (SARA) school grounds condition, codified in Executive Law § 259-c (14), violates the Ex Post Facto Clause of the United States Constitution when applied to offenders whose crimes predated the 2005 SARA amendments. Petitioner Danny Rivera, convicted in 1986 and later designated a level three sexually violent offender, faced prolonged incarceration due to his inability to find SARA-compliant housing. The court affirmed the Appellate Division's decision, holding that Rivera failed to demonstrate, by the clearest proof, that the SARA condition's effects are so punitive as to negate its civil intent, thereby not violating the Ex Post Facto Clause.