People v. McDonnell
Opinion of the Court
In this proceeding under the Sex Offender Registration Act (see Correction Law art 6-C), the Board of Examiners of Sex Offenders (hereinafter the Board) prepared a risk assessment instrument (hereinafter the RAI) assessing points under various risk factors for a toted score within risk level two. The Board’s point assessment was supported by clear and convincing evidence of the applicable risk factors, thus rendering a presumptive risk level two designation (see Correction Law § 168-d [3]; People v Pettigrew, 14 NY3d 406, 408-409 [2010]). The defendant was properly designated a “predicate sex offender” subject to lifetime registration based upon his previous convictions of sex offenses (Correction Law § 168-a [2], [7] [c]; § 168-h [2]).
The defendant contends that the County Court erred in granting the People’s application, upon the recommendation of the Board, for an upward departure to risk level three. A court may exercise its discretion and depart upward from the presumptive risk level where “it concludes that there exists an aggravating . . . factor of a kind, or to a degree, that is otherwise not adequately taken into account by the guidelines” (Sex Offender Registration Act: Risk Assessment Guidelines and Commentary,
The defendant’s remaining contention is without merit. Angiolillo, J.R, Balkin, Dickerson and Cohen, JJ., concur.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.