United State v. Helton, No. 18–4663 (4th Cir. 2019)
Nature of Case: Appellant was federally indicted for failing to register as a sex offender, and moved to dismiss the indictment. As grounds, Appellant argued that his predicate state conviction — a violation of South Carolina’s voyeurism statute — did not qualify as a sex offense for the purposes of the federal Adam Walsh Act. The trial court rejected Appellant’s argument, and he entered a conditional guilty plea which preserved his argument for appellate review.
Holding: 4th Circuit Court of Appeals affirmed the district court’s determination. A violation of South Carolina’s voyeurism statute was a sex offense for the purposes of federal SORNA — and thus he could be federally prosecuted for failing to register.