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SEXUAL OFFENDER AND REGISTRATION AND NOTIFICATION ACT “ SORNA” STATUTORY AND CONSTITUTIONAL DEFENSES PARESH S. PATEL FEDERAL PUBLIC DEFENDER, DISTRICT OF MARYLAND APRIL 6, 2012. Relevant Authority and Dates. ■ SORNA Registration Provisions (42 U.S.C. § 16901-962)

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slide1

SEXUAL OFFENDER AND REGISTRATION AND NOTIFICATION ACT “SORNA”STATUTORY AND CONSTITUTIONAL DEFENSESPARESH S. PATELFEDERAL PUBLIC DEFENDER, DISTRICT OF MARYLANDAPRIL 6, 2012

relevant authority and dates
Relevant Authority and Dates

■ SORNA Registration Provisions (42 U.S.C. § 16901-962)

Signed into law on July 27, 2006

■Criminal Failure to Register Provision (18 U.S.C. § 2250)

Signed into law on July 27, 2006

■SMART Guidelines:

Final Guidelines (73 Fed. Reg. 38030) -

Issued July 2, 2008 (Effective August 1, 2008 after notice and comm.)

Suppl. Guidelines (76 Fed. Reg. 1630)-

Issued Jan. 11, 2011

■28 C.F.R. § 72.3 (Attorney General Reg. Making SORNA retroactive to pre-enactment and pre-implementation offenders)

Interim Reg: Feb. 28, 2007; Final Reg: Jan. 28, 2011

sorna registration requirements
SORNA REGISTRATION REQUIREMENTS

■SORNA Replaces Wetterling Act

(42 U.S.C. § 14071-73)

■SORNA much more onerous:

- includes tribes and territories

- expands definition of sex offenses

- requires automatic registration w/o hearing on risk

or classification as sex offender

- requires internet posting for most offenders

- increases duration of registration for some offenders

- increases criminal penalties for failure to register

sorna registration dual obligations
SORNA Registration: Dual Obligations

■ Local Jurisdictions’ (States, Terr., Indian Tribes) Obligation: Must implement SORNA or lose money

■ Sex Offenders’ Obligation:

Individual duty to register within local jurisdictions, regardless of state’s

choice to implement SORNA.

pre implementation challenge rejected
Pre-Implementation Challenge Rejected

United States v. Gould, 568 F.3d 459 (4th Cir. 2009)

■ Defendant argued that SORNA does not apply in

states which have not yet implemented SORNA:

based on 42 U.S.C. § 16913(d) and SMART Guidelines

(73 Fed. Reg. 38064)

■ Fourth Circuit as well as every other Circuit to have decided issue has rejectedargument: holding that SORNA imposes individual duty to register separate and apart from state’s obligations.

sorna registration requirement basics
SORNA REGISTRATION REQUIREMENT BASICS

■ Initial Registration:

Each jurisdiction where sex offender resides, works, goes to school, & was convicted (if different from where resides)

Before completing term of imprisonment OR within 3 days of receiving non-prison sentence.

42 U.S.C. § 16913(a)

sorna registration requirement basics1
SORNA REGISTRATION REQUIREMENTBASICS

■Update Registration:

Within 3 days of any change to name, residence, employment or student status

Only need to update in one of the required jurisdictions, but must be in person

42 U.S.C. § 1963(b)

sorna registration requirement basics2
SORNA REGISTRATION REQUIREMENT; BASICS

■ Verify Registration:

  • In-person at each jurisdiction where required to register
  • every year (Tier I)
  • every 6 months (Tier II)
  • every 3 months (Tier III)

42 U.S.C. § 16916

failure to register 18 u s c 2250 a 2 b state sex offenses
FAILURE TO REGISTER18 U.S.C. § 2250(a)(2)(B)(State Sex Offenses)

Elements:

  • Required to register under SORNA;
  • Travels in interstate commerce, and
  • Thereafter, knowingly fails to register or

update as required by SORNA

10 year maximum penalty

failure to register 18 u s c 2250 a 2 a federal territorial and tribal sex offenses
FAILURE TO REGISTER18 U.S.C. § 2250(a)(2)(A)(Federal, Territorial, and Tribal Sex Offenses)

Elements:

  • Required to register under SORNA;

and

2)Thereafterknowingly fails to register or

update as required by SORNA

10 year maximum penalty

what constitutes a sex offense
WHAT CONSTITUTES A “SEX OFFENSE” ?

■ criminal offense that “has anelement involving a sexual act or sexual contact with another”

■ specified offense against a minor

■ certain listed federal, military, and foreign offenses

■ attempts or conspiracies

■ juvenile adj. for juveniles age 14 or older who

commit offense comparable to or > severe than

aggrav. sexual abuse under 18 U.S.C. 2241 or

attempt or conspiracy to commit such crime.

■ certain consensual sexual acts

42 U.S.C. § 16911

categorical approach and sex offense
CATEGORICAL APPROACH AND “SEX OFFENSE”

■Only elements - not underlying conduct - can qualify prior crime as “sex offense” under SORNA.

See Shepard v. United States, 544 U.S. 13 (2005);

Taylor v. United States, 495 U.S. 575 (1990)

■Attorney General has suggested categorical

approach should apply with everything except for age of victim - SMART Guidelines: 73 Fed. Reg. 38031.

categorical approach sexual act or sexual contact with another
CATEGORICAL APPROACH“SEXUAL ACT OR SEXUAL CONTACT WITH ANOTHER”

■ Requires “element involving a sexual act or sexual

contact with another.” 42 U.S.C. § 16911

■ Clause covers “all sexual offenses whose elements involve any type or degree of genital, oral, or anal penetration, or any sexual touching of or contact with a person’s body, either directly or through the clothing.” 73 Fed. Reg. 39051.

categorical approach specified offenses against a minor 42 u s c 16911
CATEGORICAL APPROACH:“SPECIFIED OFFENSES AGAINST A MINOR”42 U.S.C. § 16911

- Non-parental kidnapping or false imprisonment of a minor

- Solicitation of a minor to engage in sexual conduct

- Use of a minor in a sexual performance

- Solicitation of a minor to practice prostitution

- Video voyeurism involving a minor

- Possession, production, or distribution of child pornography

- Criminal sexual conduct involving a minor and related internet

activities

- Any conduct that, by its nature, is a sex offense against a minor,

including convictions for child molestation, sexual activity w/

underage persons and child prostitution.

categorical approach specified offenses against a minor
Categorical Approach: “Specified offenses against a minor”

■“criminal sexual conduct involving a minor” =

“sexual offenses whose elements involve physical

contact with the victim” or “offenses whose elements

involve using others persons in prostitution”

72 Fed. Reg. 38052

■ “conduct, that, by its nature, is a sex offense against a minor” =

- “status of the victim as a minor” must be element of prior offense. 73 Fed. Reg. 38052

- “by its nature” language calls for categorical approach –

See Cain v. State, 872 A.2d 682 (Md. 2005);

State v. Chun, 76 P.3d 935 (Haw. 2003)

Beware ofUnited States v. Dodge, 597 F.3d 1347

(11th Cir. 2010)

■ analogize to categorical approach used in ACCA/career offender “otherwise” clause which includes “involving conduct” language.

■ SORNA only applies to those convicted of a sex offense – not merely those who committed sex offense. 42 U.S.C. §16911 (1)

enumerated sex offenses
Enumerated “sex offenses”

■Use Model Penal Code to determine generic definition of offense.

SeeUnited States v. Peterson, 629 F.3d 432 (4th Cir. 2011).

smart guidelines re defining of sex offenses
SMART GUIDELINES: RE-DEFINING OF “SEX OFFENSES”

Beware of Attorney General’s expansion and addition of sex offenses beyond that specified by Congress in SORNA.

- Plain language of SORNA does not allow Attorney General to add new offenses and broaden SORNA’s def. of “sex offenses.”

- Attorney General not authorized to add new offenses; to read SORNA otherwise violates non-delegation doctrine.

See Panama Refining Co. v. Ryan, 293 U.S. 388 (1935).

- Constitutional Avoidance. See Clark v. Martinez, 543 U.S. 371 (2005).

Examples:

■ “Attempt” and “Conspiracy” – broadened by SMART Guidelines to include “assault with intent to rape” 73 Fed. Reg. 38051.

■ “Solicitation to engage in sexual conduct” redefined by SMART Guidelines to include “any direction, request, enticement, persuasion, or encouragement of a minor to engage in sexual conduct.” 73 Fed. Reg. 38051

valid conviction
Valid Conviction
  • Must be conviction (42 U.S.C. § 16911)
  • Convictions that are set aside, expunged, or vacated do not count (SMART Guidelines: 73 Fed. Reg. 38050)
  • Foreign conviction obtained without sufficient safeguards for due process is invalid – 42 U.S.C. § 16911 and 73 Fed. Reg. 38050 – See U.S. State Dept. Country Reports on Human Rights Practices
  • Argue that any conviction is invalid if obtained without proper waiver of counsel – U.S. v. Custis, 511 U.S. 485 (1994)
  • Argue tribal convictions invalid if no right to counsel. – Sentencing Commission does not count them, U.S.S.G. § 4A1.2
duration of registration
DURATION OF REGISTRATION:

■ Depends on Tier Level Determined by Type of Sex Offense and Prior Criminal History

under 42 U.S.C. § 16911.

42 U.S.C. § 16915.

duration of registration1
DURATION OF REGISTRATION

■ Tier I: 15 years (or 10 years if “clean record”)

Clean record:

- No convictions for offenses punishableby

more than one year; and

- No sex offense convictions; and

- No revocation of supervised release, parole, or probation; and

- successful completion of cert. sex offender treatment program

duration of registration2
DURATION OF REGISTRATION

■ Tier II: 25 years – No clean record break

■ Tier III: Life (or 25 years with clean record)

16 U.S.C. § 16915

duration of registration3
DURATION OF REGISTRATION

■ Registration period begins to run

1) upon release from custody of an offender who has been incarcerated;

2) at time of sentencing, for an offender who receives non-prison sentence.

■ Permit, but do not require jurisdictions to toll registration

while offender is incarcerated. SMART Guidelines:

73 Fed. Reg. 38068.

slide28

DURATION OF REGISTRATON CLASSES OF SEX OFFENDERS ( Tier I, II, and III)

Use categorical approach in determining tier except with respect to age of victim.

SMART Guidelines: 73 Fed. Reg. 38053.

residence
Residence

- Must register or update registration within 3 business days after sex offender establishes new “residence.” 42 U.S.C. § 16913

  • Resides: “location of the individual’s home or other place where the individual habitually lives.” 42 U.S.C. § 16911.

One “habitually lives” in a place if he stays there for 30 days.

SMART Guidelines: 73 Fed. Reg. 38062.

  • Thus, if sex offender intends to live in place for 30 days, it is a residence, and he must register within three days of moving there.

73 Fed. Reg. 38062.

residence transients
Residence: Transients
  • Beware of United States v. Bruffy, 2012 WL 503808 (4th Cir. 2012)

4th Cir. found that defendant who moved from Florida established residence at a specific location in Va., even though he lived in his car most of the 23-day period in question and

intended to get an apartment in Maryland after he found a job

there.

Because he failed to report this change of so called

residence, he was convicted of failure to update registration in Florida and failing to register in Virginia.

Seedissent – J. Gregory believes that defendant’s living situation was too transient and unstable that it was not “habitual” and therefore not “residence”

residence transients1
Residence:Transients

Even if offender does not have fixed abodes, must register with detailed information as possible of where one habitually lives (residence):

i.e., part of city that is habitual locale –

park or spot on street (or number of such places) where the sex offender stations himself during day or sleeps at night, shelters, and buildings frequented)

SMART Guidelines: 73 Fed. Reg. 38055

residence transients2
Residence: Transients
  • Sex offender must update registration when he terminates residence (leaves with no intention to return), even if he has no fixed future place of residence . SMART Guidelines: 73 Fed. Reg. 38066; See also United States v. Van Buren, 599 F.3d 170 (2d Cir. 2010); United States v. Voice, 622 F.3d 870 (8th Cir. 2010); United States v. Murphy, 664 F.3d 798 (10th Cir. 2011); United States v. Bruffy, 2012 WL 503808 (4th Cir. 2012).

But see dissent in Murphy, 664 F.3d 798 (No duty to update in former jurisdiction of residence because lang. in SORNA statute only requires reg. in jurisdiction in which one resides – not where he formerly resided)

residence transients void for vagueness
Residence: Transients Void for Vagueness

United States v. Bruffy, 2012 WL 503808 (4th Cir. 2012):

Rejected defense’s argument that the term “reside” in SORNA is unconstitutionally vague as applied to transient offenders who have vacated one residence, but have not yet established a fixed place

to live in another state.

Defense argued that SORNA fails to provide fair notice of the point in time when presence in a new jurisdiction triggers the registration requirement.

pre implementation and pre enactment offenders
Pre-Implementation and Pre-Enactment Offenders

AG has the “authority” to decide if SORNA retroactive to pre-implementation and pre-enactment offenders and prescribe rules for their registration.

42 USC 16913(d)

interim reg of attorney general 28 c f r 72 3
INTERIM REG. OF ATTORNEY GENERAL, 28 C.F.R. § 72.3

■ Effective Feb. 28, 2007

■ Makes SORNA applicable to pre-enactment and pre-imp. sex off.

■ Enacted pursuant to Congress’ directive –

42 U.S.C. § 16913(d)

■ No pre-enactment offender can be prosecuted under Failure to Register statute unless he traveled in interstate commerce and failed to register after Feb. 28, 2007.

United States v. Hatcher, 560 F.3d 222 (4th Cir. 2009)

■ Argue no pre-implementation offender can be prosecuted under Failure to Register statute unless he traveled in interstate commerce and failed to register afterFeb. 28, 2007.

United States v. Trent,654 F.3d 574 (6th Cir. 2011)

interim regulation apa challenge
Interim Regulation: APA Challenge

■ No notice and comment under Administrative Procedure Act before interim regulation, 28 C.F.R. § 72.3

■ United States v. Gould, 568 F.3d 459 (4th Cir. 2009)

No APA violation because good cause to excuse notice and comment

■ See J. Michael dissent in Gould

■ Split in the Circuits – Preserve for S.C. review

Finding APA violation:

United States v. Cain, 583 F.3d 408 (6th Cir. 2009); United States v. Utesch, 596 F.3d 302 (6th Cir. 2010); United States v. Valverde, 628 F.3d 1159

(9th Cir. 2010)

No APA violation:

United States v. Dean, 604 F.3d 1275 (11th Cir. 2010); United States v. Johnson, 632 F.3d 912 (5th Cir. 2011) (found APA violation harmless); United States v. Dixon, 551 F.3d 578 (7th Cir. 2008) (assumed w/o deciding that reg. was valid).

slide39
Interim Regulation: Standing of pre-enactment and pre-implementation offenders to make APA challenge to interim regulation

■Reynolds v. United States, 132 S. Ct. 975 (2012): Confirmed that pre-enactment offenders having standing to make APA challenge to interim regulation because the interim regulation – not Congress -- made SORNA applicable to pre-enactment offenders.

■ Under rationale of Reynolds, pre-implementation offenders also have standing to make APA challenge to interim regulation.

interim regulation 28 c f r 72 3 finalized
Interim Regulation, 28 C.F.R. § 72.3: Finalized

■ Effective January 28, 2011; 75 Fed. Reg. 81849

■ Issued after notice and comment

■ No viable APA challenge for failure to register and interstate travel afterJanuary 28, 2011

Beware of cases holding that any APA violation was cured by August 1,2008, eff. date of Final SMART Guidelines: United States v. Stevenson, __ F.3d __, 2012 WL 573326 (6th Cir. 2012);

United States v. Utesch, 596 F.3d 302 (6th Cir. 2010);

United States v. Valverde, 628 F.3d 1159 (9th Cir. 2010).

non delegation doctrine
Non-Delegation Doctrine

United States v. Burns, 2011 WL 970644 (4th Cir. 2011)

■Def. argued Congress unlawfully delegated legislative authority to Attorney General to determine retroactivity of SORNA to pre- enactment offenders.

■4th Circuit rejects argument: holds that Attorney’s authority bounded by policies and requirements set forth in SORNA.

■But unpublished decision; preserve for S.C. review even though no split in the Circuits. S.C. might take up issue along with APA challenge to interim regulation.

See dissent in Reynolds

interstate travel must occur after passage of sorna
Interstate Travel must occur after passage of SORNA

■ United States v. Carr, 130 S. Ct. 2229 (2010)

Under statutory terms of the Failure to Register statute, a sex offender can only be prosecuted if he traveled in interstate commerce after the enactment of SORNA on July 27, 2006.

■ But in Fourth Circuit under Hatcher, 560 F.2d 222, travel for pre-enactment and pre-imp. offenders must be not only after July 27, 2006, but also after February 28, 2007– date of interim regulation applying SORNA to pre-enactment and pre-imp. offenders.

■ But remember to preserve argument that travel for pre- enactment and pre-imp offenders must be after

Jan. 28, 2011 – only then did AG issue valid reg. after n and c.

sorna registration requirement unable to comply with sorna
SORNA REGISTRATION REQUIREMENT: Unable to Comply with SORNA

AG must prescribe rules for registration of people unable to comply with SORNA’s initial registration requirements.

42 USC §16913(d); 42 USC §16913(b)

group of offenders unable to comply with sorna
Group of Offenders Unable to Comply withSORNA

■Gould, 568 F.3d 459

-Def. argued that he was unable to initially register under 42 U.S.C. § 16913(b) because he was released from prison on underlying sex offense beforeSORNA was enacted.

- Fourth Circuit rejected argument: held sex offender isable to comply with SORNA if required to register under state law.

■Kennedy v. Allera, 612 F.3d 261 (2010) (Gets even worse)

-Def. argued that he was unable to initially register because he was not required to register under state law.

- In conflict withGould, Court held that a sex offender is able to comply with SORNA as long as a state sex offender registry exists – even if he is not required to register under state law.

group of offenders unable to comply with sorna1
Group of Offenders Unable to Comply with SORNA

■See SMART Guidelines Examples:

38 Fed. Reg. 38063

Make plain that sex offenders are unable to comply with SORNA if not required to register under state law.

■Make constitutional avoidance argument: if not required to register, will get no notice required under due process.

duty to notify and ensure registration 42 usc 16917 a
Duty to Notify and Ensure Registration, 42 USC 16917(a)

An appropriate official shall, shortly before release of the sex offender from custody, or, if the sex offender is not in custody, immediately after the sentencing of the sex offender, for the offense giving rise to the duty to register--(1) inform the sex offender of the duties of a sex offender under this title and explain those duties;

(2) require the sex offender to read and sign a form stating that the duty to register has been explained and that the sex offender understands the registration requirement; and

(3) ensure that the sex offender is registered.

notice statutory requirement
Notice – Statutory Requirement

Gould, 568 F.3d 459

■Statutory argument:

Def. argued that he could not be punished for “knowingly” failing to register because SORNA has affirmative notice provision under

42 U.S.C. § 16917.

Fourth Circuit rejected: held that Failure to Register general intent crime; knowledge of facts constituting crime required- not knowledge of law itself.

However, in Reynoldsoral argument, the Solicitor General said the following:

SORNA “require[s] that any failure to register, in order to be subject to prevailing sanctions, that it be a knowing failure to register. In other words, that the offender know he has a registration requirement and know that he is complying with that requirement.”

See also dissent inUnited States v. Vasquez, 611 F.3d 325 (7th Cir. 2010)

notice constitutional due process
Notice – Constitutional Due Process

Gould, 568 F.3d 459

■Constitutional Due Process:

Def. argued that passive activity of failing to register cannot be

punished without notice under

Lambert v. California, 355U.S.255 (1957).

Fourth Circuit rejected: held that as long as one has notice of duty to register under state law, no additional notice of SORNA required; he knows he is engaging is some wrongdoing. Other Circuits have held the same.

■ If defendant did not have notice of duty to register under state law or SORNA, then you have good due process argument.

commerce clause
Commerce Clause

Gould, 568 F.3d 459,

Defendant argued:

■ SORNAreg. provision (42 U.S.C. 16913)violates Commerce Clause because

- No Interstate Commerce Element;

- No Substantial Effect on Interstate Commerce –

No Economic Activity

■ Failure to Register Statute (18 USC 2250(a)(2)(B)) violates Commerce Clause

- No Nexus Required Between Interstate Travel and Failure to Register

- No Substantial Effect on Commerce – No Economic Activity

Fourth Circuit rejected both arguments:

- Substantial effect on commerce because SORNA is part of larger comprehensive interstate national problem; SORNA enacted to preclude avoidance of registration thru flight across state lines:

- No nexus required between travel and harm regulated.

But See great dissent: United States v. Vasquez, 611 F.3d 325 (7th Cir. 2010)

commerce clause1
Commerce Clause

Failure to Register Statute (18 USC 2250(a)(2)(A)) – For federal offenses:

No travel requirement, yet courts thus far have upheld under Necessary and Proper Clause either:

1) because it is necessary and proper to carry out Congress’ supervisory power over federal offenders,

or

2) because it is necessary and proper to effectuate Congress’ Commerce Clause power.

United States v. George, 625 F.3d 1124 (9th Cir. 2010) (pending en banc); United States v. Kebodeaux, 647 F.3d 137 (5th Cir. 2011); United States v. Carel, __F.3d__, 2011 WL 6880674 (10th Cir. 2011); United States v. Yelloweagle, 643 F.3d 1275 (10th Cir. 2011)

tenth amendment commandeering
Tenth Amendment: Commandeering

Kennedy v. Allera, 612 F.3d 261

■ Defendant argued that by requiring him to register in a state in which he was not required to do so under state law, feds were forcing state to comply with federal law – SORNA.

■ Fourth Circuit rejected argument: feds did not put demand on state to register defendant; state’s choice to reject defendant’s registration

ex post facto generally
Ex Post Facto (Generally)

United States v. Burns, 2011 WL 970644 (4th Cir. 2011)

■ Def. argued that requiring pre-enactment sex offenders to register results in ex post facto punishment; SORNA is punitive

■ Fourth Circuit did not decide issue. Continue to preserve although no love from other Circuits.

ex post facto juveniles
Ex Post Facto - Juveniles

United States v. Juvenile Male, 590 F.3d 924

(9th Cir. 2010)

■ Retroactive application of SORNA to a juvenile adjudicated delinquent prior to SORNA – ex post facto violation.

Disclosure of juvenile info (historically shielded from public) is punitive – severely damaging to economic, social, psychological, and physical well being of juveniles.

Beware: Supreme Court dismissed case for mootness because sex offender registration condition ended with def.’s 21stbday,

131 S. Ct. 2860 (2011) - Still use rationale.

See also United States v. W.B.H., 664 F.3d 848

(11th Cir. 2011) (No ex post facto viol. for Youthful Offender Act conviction).

venue
Venue

■United States v. Burns, 2011 WL 970644,

- Def. argued that because client failed to register in Ca.,

Va. was improper venue for Failure to Register prosecution.

- Fourth Circuit rejected arg. because travel started in Va. – travel part of offense conduct.

■United States v. Pietrantonio, __ F.3d __, 2011 WL 869477

(8th Cir. 2011)

- Improper venue if neither travel or failure to register connected

to federal district of prosecution.

duplicitous indictment
Duplicitous Indictment

United States v. Pietrantonio,

637 F.3d 865 (8th Cir. 2011)

- Two separate and distinct failure to register allegations cannot be charged in one count

of an indictment.

affirmative defense 18 u s c 2250
Affirmative Defense: 18 U.S.C. § 2250
  • Uncontrollable Circumstances prevented defendant from complying with SORNA;
  • He did not contribute to the creation of such circumstances in reckless disregard of requirement to comply; and
  • Complied as soon as circumstances ceased to exist.
supervised release conditions
Supervised Release Conditions

Under 18 U.S.C. § 3583(d), conditions

1) must be reasonably related to goals of sentencing;

2) must involve no greater dep. of liberty than necessary to deter criminal conduct,

protect the public, and provide for def.’s educ.,

vocational, medical, and corr. needs;

3)must be individualized

supervised release conditions1
Supervised Release Conditions

Conditions continued

4) must not delegate unbridled discretion to the probation officer; and

5) must not impinge on First Amendment rights.

supervised release conditions2
Supervised Release Conditions
  • Conditions invalidated by courts:
  • Movement restrictions – no coming within 500 feet of schools, yards, parks, arcades, etc. United States v. Smith, 655 F.3d 839 (8th Cir. 2011)
  • Possessing pornography in any form – United States v. Curry, 627 F.3d 312 (8th Cir. 2010)
  • Possessing any material, legal or illegal, that contains nudity or that depicts or alludes to sexual activity -

United States v. Simons, 614 F.3d 475 (8th Cir. 2010)

supervised release conditions3
Supervised Release Conditions
  • Polygraph testing ok if incriminating statements not compelled in violation of Fifth Amendment.

See United States v. Talada, 2010 WL 2182204

(4th Cir. 2010)

resources
RESOURCES

www.fd.org

Paresh_patel@fd.org

Christine_lee@fd.org

Candace_Cain@fd.org

(brief bank on SORNA issues)

good summary smart guidelines
GOOD SUMMARY: SMART GUIDELINES
  • Summary of Final National Guidelines for Sex Offender Registration and Notification For Implementation of SORNA,

National Conference of State Legislatures, Jan. 2009.

  • Supplemental SORNA Guidelines,

National Conference of State Legislatures, May 2010.

http://www.ncsl.org