United States v. Holcombe, 883 F.3d 12 (2nd Cir. 2018)
Nature of Case: Appellant was convicted of failing to register under SORNA after traveling interstate and failing to update his registration. At the trial court he raised numerous issues, all of which were rejected and he was convicted. Appellant sought review, alleging that his conviction was improper on venue grounds, and furthermore that SORNA was unconstitutionally vague and violated his right to interstate travel.
Holding: 2nd Circuit Court of Appeals affirmed. Venue was proper in the SDNY, and furthermore on the facts of Appellant’s case (having lived outside of New York for some time) there was no vagueness issue under SORNA with respect to the use of the word “resides.” Finally, SORNA does not implicate the right to engage in interstate travel or — if it does — those burdens are necessary to promote a compelling governmental interest.