Hope v. Commissioner of Indiana Department of Correction, No. 22-2150 (7th Cir. 2023)
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The Indiana Sex Offender Registration Act (SORA) requires sex offenders who study, work, or reside in Indiana to register with the state. Indiana residents who committed sex offenses either before the Indiana General Assembly enacted SORA or before the Assembly amended SORA to cover their specific offense challenged, under the Equal Protection Clause, SORA’s “other-jurisdiction” provision. That provision requires them to register under SORA because they have a duty to register in another jurisdiction. The Seventh Circuit previously rejected arguments that SORA violated the constitutional right to travel and the Ex Post Facto Clause and concluded that the district court incorrectly applied strict scrutiny to the equal protection claim, remanding for a determination of whether the other-jurisdiction provision survives rational basis review. On remand, the district court concluded that requiring the registration of pre-SORA sex offenders who have a registration obligation in another jurisdiction is not rationally related to a legitimate state interest and granted the plaintiffs summary judgment.
The Seventh Circuit reversed. Indiana has a legitimate interest in seeking to register as many sex offenders as the state constitution permits; SORA’s other-jurisdiction provision is rationally related to advancing that interest. The Indiana Supreme Court has held that when an offender is already obligated to register elsewhere, requiring registration in Indiana merely extends that existing duty, which is not punitive and does not offend Indiana’s Ex Post Facto Clause.
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