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State Law Registration Requirements Trigger SORNA
On December 15, 2009, the U.S. Court of Appeals for the Eleventh Circuit upheld a sex offender’s conviction under the Sex Offender Registration and Notification Act (SORNA).
David Griffey was convicted of a sex offense in Illinois, but later moved to Alabama after his release. Griffey failed to register in Alabama as a sex offender.
Griffey was indicted under SORNA for failing to register. Griffey challenged his conviction arguing that (1) SORNA did not apply to him because Alabama had not implemented SORNA at the time he failed to register, and (2) he was never notified by state or federal authorities of his duty to register under SORNA.
The Eleventh Circuit rejected both arguments holding first that SORNA applied to him regardless of whether SORNA had been implemented in Alabama because Alabama had its own sex offender registration law. Consequently, Griffey was required to register. Furthermore, the court held, Griffey had sufficient notice that he was required to register given Griffey’s admission that he knew he was supposed to register.
Griffey’s conviction was accordingly affirmed. See: United States v. Griffey,
589 F.3d 1363 (11th Cir. 2009).
David Griffey was convicted of a sex offense in Illinois, but later moved to Alabama after his release. Griffey failed to register in Alabama as a sex offender.
Griffey was indicted under SORNA for failing to register. Griffey challenged his conviction arguing that (1) SORNA did not apply to him because Alabama had not implemented SORNA at the time he failed to register, and (2) he was never notified by state or federal authorities of his duty to register under SORNA.
The Eleventh Circuit rejected both arguments holding first that SORNA applied to him regardless of whether SORNA had been implemented in Alabama because Alabama had its own sex offender registration law. Consequently, Griffey was required to register. Furthermore, the court held, Griffey had sufficient notice that he was required to register given Griffey’s admission that he knew he was supposed to register.
Griffey’s conviction was accordingly affirmed. See: United States v. Griffey,
589 F.3d 1363 (11th Cir. 2009).
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Related legal case
United States v. Griffey
| Year | 2009 |
|---|---|
| Cite | 589 F.3d 1363 (11th Cir. 2009) |
| Level | Court of Appeals |
| Injunction Status | N/A |