United States First Circuit

Conviction for failing to comply with the Sex Offender Registration and Notification Act (SORNA) is affirmed, where: 1) the Attorney General had issued the SMART Guidelines implementing retroactivity of SORNA, which are valid and do not condition retroactivity on the jurisdiction's implementation of SORNA; and thus, 2) although defendant's predicate sex-offender conviction predates SORNA, defendant was subject to SORNA's registration requirements when he moved from the District of Columbia to Massachusetts in 2009 and then failed to register as a sex offender in Massachusetts.

Appellate Information

• Decided 04/18/2013
• Published 04/18/2013

Judges

• STAHL

Court

• United States First Circuit

Counsel