State v. Boyd (Wash. Ct. App. 2017)

State v. Boyd, 408 P.3d 362 (Wash. Ct. App. 2017)

Nature of Case: Appellant was convicted in Washington State Court of crimes, inter alia, failure to register as a sex offender stemming from a 1999 sex offense. Appellant was homeless, and per state law, was required to update his registration in-person weekly. Appellant was convicted after a jury trial and appealed, contending that state statute requiring frequent in-person reporting requirements was punishment and therefore violated Ex Post Facto Clause of US Constitution.

Holding:  Held: Trial court affirmed. Weekly, in-person registration requirement was not so burdensome as to be punitive.

[Ed. Note: Counsel for Boyd has filed a petition for certiorari to the United States Supreme Court].