People v. Washington

Memorandum: Defendant appeals from an order determining that he is a level two risk pursuant to the Sex Offender Registration Act (Correction Law § 168 et seq.). Contrary to defendant’s contention, County Court’s determination that he established a relationship with the victim for the purpose of victimization is supported by the requisite clear and convincing evidence (see § 168-n [3]). “The guidelines assess 20 points if the offender’s crime . . . was directed at ... a person with whom a relationship had been established . . . for the primary purpose of victimization” (Sex Offender…