Michigan v. Dowdy
Annotate this CaseAt issue in this case was whether homeless sex offenders are obligated to comply with the registration requirement of the state Sex Offenders Registration Act (SORA). Specifically, the issue centered on whether homeless offenders have a "residence" or "domicile" as defined by SORA. In 1984, Defendant Randal Dowdy pled guilty to kidnapping and first-degree criminal sexual conduct. He remained incarcerated until 2002. As a consequence of his sex crime conviction, he was required to register as a sex offender. Defendant registered his address as that of a homeless shelter. When the shelter discovered that he was a sex offender, he was kicked out pursuant to the shelter's policies barring sex offenders from receiving its services. In 2006 when police attempted to verify where Defendant had lived, they discovered that Defendant had not maintained his SORA registration since leaving prison. The circuit court dismissed charges against Defendant pertaining to his failure to register, holding that Defendant's homelessness rendered it impossible for him to comply with SORA. Upon review, the Supreme Court held that homelessness was not a bar to compliance with SORA because homelessness "does not preclude an offender from entering a police station and reporting to a law enforcement agency regarding the offender's residence or domicile." The Court reversed the lower courts and remanded the case for further proceedings.
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