United States v. Walker, No. 18-3529 (7th Cir. 2019)
Annotate this CaseWalker sexually assaulted his four‐ and six‐year‐old nephews. In 1998, he pleaded guilty under a Colorado law that prohibits sexual contact with a child under 15 by anyone who is a least four years older than the child and was sentenced to four years’ probation. His probation was later revoked, and he served a prison term. After his release, Walker had to register under the Sex Offender Registration and Notification Act (SORNA), which imposes a progressive registration scheme that tracks the severity of the offense, 34 U.S.C. 20915(a). In 2017, Walker was indicted for failing to register as a sex offender after June 2016, 18 U.S.C. 2250(a). Walker argued that his 1998 conviction was only a Tier I SORNA offense so that his obligation to register ended 15 years after his conviction. Walker entered a conditional guilty plea. The Seventh Circuit vacated his conviction, first stating that SORNA’s text compels a hybrid approach—part categorical and part circumstance‐specific—when comparing the defendant’s conviction to the SORNA categories. Because Walker’s Colorado conviction is not a categorical match with “abusive sexual contact (as described in section 2244 of title 18),” he does not qualify for Tier II or Tier III status regardless of the ages of his victims.
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