California Court of Appeal

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People v. Milligan, G039546

Conviction and sentence for failing to register as a sex offender are affirmed with proviso that defendant is not subject to the Sexual Predator Punishment and Control Act: Jessica's Law's (SPPCA) residency restrictions and GPS monitoring requirements because they do not apply retroactively. The conviction is affirmed where: 1) defendant's challenge to the 2005 amendment to section 290 is not ripe for adjudication; and 2) under well-established authority, other challenged amendments and additions do not constitute punishment.

Appellate Information

  • Decided 09/16/2008
  • Published 09/16/2008



  • California Court of Appeal


  • For Appellees:
  • Jackie Menaster, Los Angeles, under appointment by the Court of Appeal, for Defendant and Appellant., Edmund G. Brown, Jr., Attorney General, Dane R. Gillette, Chief Assistant Attorney General, Gary W. Schons, Assistant Attorney General, Janet Neeley and Donald W. Ostertag, Deputy Attorneys General, for Plaintiff and Respondent.
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