Commonwealth v. Haines, 2019 PA Super 329 (Pa. Super. 2019)
Nature of Case: Appellant had committed sexual offenses as a juvenile, though did not enter a guilty plea to the offenses until she reached adulthood. She contended, in line with Pennsylvania caselaw, that she should not be required to register as a sex offender as it would constitute an impermissible ex post facto law.
The lower court disagreed, and order Appellant to register as a sex offender. Appellant thereafter sought review.
Holding: Pennsylvania Superior Court reversed the decision of the lower court. Under the Pennsylvania Supreme Court’s decision In re J.B., requiring automatic lifetime sex offense registration for juveniles is unconstitutional. The essential holding of J.B. applies with equal force in Appellant’s case, notwithstanding the fact that she was convicted as an adult, because she had committed the offenses as a juvenile.