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    Mitchell Hamline School of Law, located in St. Paul, Minnesota offers a rigorous, practice-based experience, preparing graduates to serve clients and communities. Our motivated students study full time or part time, on-campus or partially online in the way that fits their lives.

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Sex Offense Litigation and Policy Resource Center

SORN

Litigation and Policy Resource Center

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Search SOLPRC

Recent Cases

  • People v. Superior Court of Santa Cruz County (Cal. Ct. App. 2023)

  • North Carolina v. Lamp (N.C. 2022)

  • Matter of Stevens (Wash. 2022)

  • United States v. Navarro (5th Cir. 2022)

  • McDeid v. Johnston (Minn. 2023)

  • Doe v. Department of Justice (C.D. Cal. 2023)

  • In re T.O. (Cal. Ct. App. 2022)

  • People v. Kastman (Ill. 2022)

  • State v. McMahon (La. Ct. App. 2022)

  • Commonwealth v. Roderick (Mass. 2022)

Contact Information

Sex Offense Litigation and Policy Resource Center

875 Summit Avenue
Saint Paul, MN 55105

Professor Eric Janus, Director

eric.janus @mitchellhamline.edu

Madeline Ranum, Policy Fellow

651-695-7638

madeline.ranum @mitchellhamline.edu

People v. Talluto (N.Y. 2022)

Posted: February 15, 2023
New York Court of Appeals opinion holding that SORA requires persons subject to its foreign registration requirements to be designated as “sexually violent” regardless of whether their underlying offense was violent in nature.

People v. Talluto (N.Y. 2022)

Category: SORN Cases Tag: New York, Second Circuit, SORA, SORN

In re T.O. (Cal. Ct. App. 2022)

Posted: November 18, 2022
California Court of Appeals opinion affirming lower court and holding that under California law Juvenile Court lacked authority to impose sex offense registration requirements upon juvenile who was not committed to Division of Juvenile Justice.

In re T.O. (Cal. Ct. App. 2022)

Category: SORN Cases Tag: California, Juvenile, SORN

State v. Larson (Minn. 2022)

Posted: November 17, 2022
Minnesota Supreme Court opinion holding that, under Minnesota law, separate convictions for failure to register involving the same assignment of a corrections agent violated prohibitions against double jeopardy.

State v. Larson (Minn. 2022)

Category: SORN Cases Tag: Double Jeopary, Failure to Register, Minnesota, SORN

Doe as Next Friend of Doe #6 v. Swearingen (11th Cir. 2022)

Posted: November 17, 2022
Eleventh Circuit opinion holding that the continuing violation doctrine applies to required registrants' claims based on reputational injury and regular reporting requirements in challenge to constitutionality of sex offense registration law.

Doe as Next Friend of Doe #6 v. Swearingen (11th Cir. 2022)

Category: SORN Cases Tag: 11th Cir., Continuing Violation, SORN, Statute of Limitations

Interest of C.G. (Wis. 2022)

Posted: August 16, 2022
Wisconsin Supreme Court rejects transgender woman's challenge to Wisconsin registry based on registry provision preventing registrants from legally changing their names, concluding that (1) under well established precedent, placement on the registry is not a “punishment” under the Eighth Amendment and, even if it was, registration is neither cruel not unusual, and (2) petitioner’s right to free speech does not encompass the power to compel the State to facilitate a change of her legal name.

Interest of C.G. (Wis. 2022)

Category: SORN Cases Tag: Eighth Amendment, First Amendment, SORN, Transgender, Wisconsin

Lindsey v. Swearingen (N.D. Fla. 2022)

Posted: March 5, 2022
District Court holding rejecting Full Faith and Credit Clause and Equal Protection arguments and holding, first, that Florida may require a new resident to register as a "sex offender" based on a crime committed in a state where the individual lived previously, even though a court in that state terminated that state's registration requirement and, second, that Florida is not required to purge or deny public access to prior registration records where an individual has left the state.

Lindsey v. Swearingen (N.D. Fla. 2022)

Category: SORN Cases Tag: Equal Protection, Florida, Full Faith and Credit, SORN

Atryzek v. State of Rhode Island (R.I. 2022)

Posted: March 5, 2022
Rhode Island Supreme Court opinion in postconviction registry challenge affirming Superior Court's judgment in part and quashed the judgment in part, concluding that Defendant is no longer required to register, that dates of alleged offenses, not dates of conviction, controlled whether a registration duty was violated, and that the state's argument that earlier convictions gave rise to new independent duty to register was outside the scope of remand.

Atryzek v. State of Rhode Island (R.I. 2022)

Category: SORN Cases Tag: Failure to Register, Postconviction, Rhode Island, SORN

Gardei v. Conway (Ga. 2022)

Posted: March 5, 2022
Supreme Court of Georgia opinion holding that two-year statute of limitations did not bar Appellant's registry challenge seeking prospective declaratory relief due to the recurring annual nature of the registration requirement imposed on Appellant.

Gardei v. Conway (Ga. 2022)

Category: SORN Cases Tag: Georgia, SORN, Statute of Limitations

People v. Edwards (N.Y. App. Div. 2021)

Posted: January 6, 2022
New York Appellate Division Fourth Department decision reversing a lower court's determination of risk level under SORA finding that the lower court erred in concluding that defendant failed to identify and establish the existence of a mitigating factor not taken into account by the guidelines, where defendant established by a preponderance of the evidence that he had not reoffended for seven years between release from prison and the SORA hearing, despite being unsupervised.

People v. Edwards (N.Y. App. Div. 2021)

Category: SORN Cases Tag: Mitigating Factors, New York, Risk Level, SORN

Topics

Jurisdiction

10th Cir. 11th Cir. 1st Cir. 2nd Cir. 3rd Cir. 4th Cir. 5th Cir. 6th Cir. 7th Cir. 8th Cir. 9th Cir. 9th Circuit Alabama Alaska Arizona California Colorado Connecticut D.C. Cir. Florida Georgia Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Neb. Nebraska New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania South Carolina South Dakota Tennessee Texas United States Supreme Court Utah Vermont Virginia Vt. Washington Wisconsin

Constitutional Issues

10th Amendment 14th Amendment 1st Amendment 4th Amendment 5th Amendment 6th Amendment 8th Amendment Assistance of Counsel Bail Bill of Attainder Compelled Speech Double Jeopardy Due Process Equal Protection Ex Post Facto Foreign Commerce Clause Fourteenth Amendment Freedom of Association Full Faith and Credit Habeas Corpus Necessary and Proper Nondelegation Overbreadth Privileges and Immunities Procedural Due Process Right to Jury Trial Right to Parent Right to Travel Ripeness Speedy Trial Standing Substantive Due Process Takings Clause Treaty power Void-for-Vagueness

Substantive Issues

Actual Innocence Administrative exhaustion Administrative Procedures Act AEDPA Antisocial Personality Disorder Apprendi / Alleyne As-Applied AWA Burden of Proof Churches Civil Commitment Collateral Estoppel Conditions of Confinement Conditions of Release Daubert Deregistration Evidentiary Standards Expungement Extraterritorial Registration Failure to Register Familial Relationships GPS Halloween Hearsay Heck bar Homelessness Housing HUD Immigration Ineffective Assistance International Travel Internet Identifiers Internet Restrictions Jury Instructions Juvenile Registration Mental disorder Non-Sexual Offense Notification Out-of-state Offense Paraphilia Diagnosis Pardon Parole Personality Disorder Plea Agreement Plethysmograph PLRA Polygraphs Preemption Presence Restrictions Procedural Default PROTECT Act Punishment Qualified Immunity Recidivism Reclassification Res Judicata Residential Banishment Retroactive Application (Non-EPF) Revocation of Supervision Risk School Property Second / Subsequent Offense Sentencing Sexual Predator designation Sign Posting Special Needs Supervised Release SVP Tiering / Classification Tolling Transitional Release Travel Travel Restrictions Treatment Programs Voting Rights





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