United States v. Crowder, No. 10-30125 (9th Cir. 2011)Annotate this Case
Defendant was convicted of child molestation in Washington state and sentenced to two years confinement. At issue was whether the government must prove that a defendant knew that the Sex Offender Registration and Notification Act (SORNA), 18 U.S.C. 2250(a), imposed a registration requirement in order to convict a defendant of a violation of this statute. The court joined its sister circuits in holding that the government need not prove this knowledge element. In this instance, although defendant did not receive notice of the requirement to register under SORNA, the government did not have to prove that he knew of this requirement in order to convict him of an offense under section 2250. Defendant was required by the terms of his judgment to register in Washington as well as in any new state to which he moved. Therefore, the court held that there was ample evidence on which the district court could base its determination that defendant knew he was required to register and failed to do so. Accordingly, the court rejected defendant's challenge to the sufficiency of the evidence.