Doe v. Jindal, 851 F.Supp.2d. 995 (E.D. La. 2012)
Nature of Case: Plaintiffs brought civil rights against against Louisiana officials regarding the state’s Crime Against Nature by Solicitations (CANS) statute, which criminalized soliciting or offering oral or anal sex. CANS statute originally required registration as sex offenders for violation, but was amended in 2011 to no longer require sex offender registration, but this amendment was not made retroactive. Louisiana furthermore had a companion prostitution statute which did not require registration. Plaintiffs were individuals with pre-2011 CANS convictions and were required to register as sex offenders in Louisiana.
Holding: District Court for the Eastern District of Louisiana held that requiring plaintiffs to register as sex offenders for CANS convictions violated 14th Amendment Equal Protection. Requiring individuals in plaintiffs position, but not those with post-2011 convictions nor convictions for related prostitution statute, to register as sex offenders was not rationally related to achieving any legitimate state interest.