State v. Habtai, No. 76627-9– I (Wash. Ct. App. Div. I 2018)
Nature of Case: Appellant was convicted of a kidnapping offense and ordered by the trial court to register. Appellant argued that, since elements of his offense did not specify age of his victim or biological relationship, trial court exceeded its authority under Apprendi to order registration. Trial court rejected argument, and appeal resulted.
Holding: Washington Court of Appeals held that registration was non-punitive in nature, subsequent amendments notwithstanding, and therefore that the trial court did not offend Apprendi principles in ordering registration.