CA2: Even if SORA was a search and seizure it would be reasonable under special needs

Even if the New York Sex Offender Registration Act constituted a search and seizure or implicated the Fourth Amendment at all [which is not clear or obvious], it would survive special needs analysis. Doe v. Cuomo, 2014 U.S. App. LEXIS 11198 (2d Cir. June 16, 2014):

Lastly, Doe argues that the registration requirements violate his Fourth Amendment right to be free from unreasonable searches and seizures. Even if we assume for argument that SORA’s requirements subject Doe to a search or seizure for Fourth Amendment purposes, we cannot agree that any such search or seizure is unreasonable. Here, any searches or seizures required by SORA serve special needs—such as the protection of potential future victims and the solving of crimes in the future—and purport neither to facilitate the investigation of any specific crime nor primarily to serve a “general interest in crime control.” See Nicholas v. Goord, 430 F.3d 652, 663, 669 (2d Cir. 2005); Roe v. Marcotte, 193 F.3d 72, 79 (2d Cir. 1999). Moreover, the degree of intrusion on convicted sex offenders is reasonable in relation to the interests advanced by SORA. See Illinois v. Lidster, 540 U.S. 419, 425-26, 124 S. Ct. 885, 157 L. Ed. 2d 843 (2004). We therefore conclude that SORA, as amended and as applied to Doe, does not run afoul of the Fourth Amendment.