State v. DonaldsonAnnotate this Case
Defendant, who challenged the registration requirements of the Kansas Offender Registration Act (KORA) as applied to violent offenders, was unable to satisfy the “clearest proof” standard because the record had not been sufficiently developed.
Defendant was convicted of one count each of aggravated kidnapping, aggravated battery, and criminal intent. The trial court sentenced Defendant to a term of imprisonment and imposed lifetime registration pursuant to KORA. At the time he committed the crimes, Defendant would have been subject to registration only if the victim of the aggravating kidnapping charge under under age eighteen. After the State charged Defendant but prior to trial, the legislature amended KORA in such a away that Defendant was subject to lifetime registration. The court of appeals affirmed Defendant’s conviction and sentence. The Supreme Court also affirmed for the aforementioned reasons.