A New York appellate court has upheld the designation of Jeffrey J. Dreyer as a level two sex offender. This ruling affects Dreyer, who was convicted of attempted possession of a sexual performance by a child. The decision emphasizes the seriousness of his offenses and the court's commitment to protecting potential victims.

The Appellate Division of the Supreme Court of the State of New York made its ruling on November 4, 2026, in case number 2025-12218. The court affirmed a previous order from the County Court of Suffolk County, which had assessed Dreyer's risk level based on the nature of his crimes. This ruling is significant as it underscores the legal framework surrounding sex offender registrations and the criteria used to determine risk levels.

Background

The case involves Jeffrey J. Dreyer, who was convicted after pleading guilty to attempted possession of a sexual performance by a child. This crime falls under the New York State's Sex Offender Registration Act (SORA), which mandates that individuals convicted of certain sexual offenses register as sex offenders and undergo risk assessments to determine their level of danger to the community.

The dispute arose after a hearing where the County Court assessed Dreyer a total of 80 points on the risk assessment instrument. This assessment led to his designation as a level two sex offender. Dreyer appealed this designation, arguing that the points assigned to him were improperly assessed.

The case reached the Appellate Division after the County Court's decision in July 2025. The appeal focused on whether the evidence presented during the hearing justified the points assigned under the risk assessment guidelines.

The Ruling

The Appellate Division ruled to affirm the County Court's designation of Dreyer as a level two sex offender. The court found that the County Court had properly assessed 30 points under risk factor 5 of the risk assessment instrument. This factor considers the age of the victims depicted in the materials possessed by the offender.

The court ruled, "the People established, by clear and convincing evidence, that at least one of the victims depicted in the video files that he possessed was 10 years old or less."

Evidence presented included testimony from a criminal investigator who recovered the files from Dreyer's phone. The investigator estimated the ages of the children in the videos to be between 4 and 7 years old. The court also noted that corroborating screenshot images of the files were introduced into evidence during the SORA hearing.

Additionally, the court assessed 20 points under risk factor 7, which pertains to the nature of the relationship between the offender and the victim. The court found that Dreyer had met a 16-year-old victim on Snapchat, and any relationship that developed was primarily for the purpose of victimization. This finding was supported by the nature of the sexually explicit messages and photographs exchanged before Dreyer attempted to meet the victim.

Impact

This ruling has significant implications for the future of sex offender designations in New York. By affirming Dreyer's designation, the court reinforces the importance of thorough risk assessments in determining the potential danger posed by offenders. This case highlights the legal system's commitment to protecting vulnerable populations, particularly children.

The decision may also influence similar cases involving sex offender registrations, as it sets a precedent for how courts evaluate evidence and assess risk factors. It emphasizes the need for clear and convincing evidence when determining the age of victims and the nature of relationships between offenders and their victims.

What's Next

Details were not available in the court filing regarding whether Dreyer plans to appeal this decision further. However, given the nature of the case, it is possible that he may seek further legal recourse. There are no related cases pending that were mentioned in the opinion.