Lozier v. State (Miss. 2019)

Lozier v. State, No. 2018-CA-00795-SCT (Miss. 2019)

Nature of Case: Appellant was convicted of a sexual offense in Massachusetts in 1996, and in 2006 moved to Mississippi and began to register as a sex offender pursuant to Mississippi state law.

Thereafter, Massachusetts notified Appellant that he no longer was required to register as a sex offender under Massachusetts state law. Appellant thereafter filed a petition in Mississippi to cease his registration requirement. The trial court denied Appellant’s petition on the grounds that he had not yet met the criteria for terminating his registration requirement under Mississippi state law. Appellant sought review.

Holding: Mississippi Supreme Court affirmed the decision of the trial court denying Appellant’s petition. The Court held that under state law, Appellant had not yet reached the time period when he would be eligible to terminate his registration requirement in Mississippi. Further, the Court rejected Appellant’s argument that the Full Faith and Credit clause would require Mississippi to honor Massachusetts’ determination that Appellant no longer had to register.