State v. Straw, No. 19A-CR-934 (Ind. Ct. App. 2019)
Nature of Case: Appellant was convicted of voyeurism, for which the Indiana legislature had not mandated sex offense registration. As a condition of Appellant’s probation, the trial court ordered Appellant to register as a sex offender. Appellant appealed on the grounds that such a requirement was not within the discretion of the trial court.
Holding: Indiana Court of Appeals reversed, holding that had the Indiana legislature intended for Appellant’s offense to carry with it registration it could have easily done so. Because Appellant’s offense was not one for which registration was a possible consequence, the trial court abused its discretion in ordering it in Appellant’s Case.