Lamberty v. State

Summary

The Delaware Supreme Court affirmed Juan Lamberty’s conviction for failure to properly report as a registered sex offender. The Court held that Delaware’s more frequent registration requirement for homeless Tier II sex offenders was rationally related to legitimate governmental interests and that the statutory delegation to the Delaware State Police Superintendent was lawful.

Holdings

1. 11 Del. C. § 4121(k) does not violate the Equal Protection Clause because the distinction between homeless sex offenders and sex offenders with permanent residences is rationally related to the legitimate governmental interest in monitoring sex offenders and protecting the public.
2. The Sex Offender Registration Statute lawfully delegates administrative authority to the Superintendent of the Delaware State Police because it provides an objectively reasonable standard for designating reporting locations and limits the Superintendent's discretion to implementing the legislative policy.

Questions Presented

1. Whether the Sex Offender Registration Statute, particularly 11 Del. C. § 4121(k), violated the Equal Protection Clause by requiring homeless sex offenders to register more frequently than sex offenders with permanent residences.
2. Whether the Sex Offender Registration Statute unlawfully delegated legislative power to the Superintendent of the Delaware State Police by authorizing the Superintendent to designate reporting locations.

Disposition

affirmed