United States v. Helton, No. 18-4663 (4th Cir. 2019)
Annotate this CaseA conviction under South Carolina's voyeurism statute constitutes a sex offense requiring registration under the Sexual Offender Registration Act (SORNA). The Fourth Circuit declined to apply the section 2246 definitions of "sexual act" and "sexual contact" outside of their place in Title 18 Chapter 109A, in the absence of statutory language to do so. Rather, the court chose to define SORNA's use of these terms in accordance with their ordinary meaning. Consequently, the court explained that a violation of the voyeurism statute—which does not require physical contact, but does require the voyeuristic act to be in furtherance of "arousing or gratifying sexual desire"—is a criminal offense involving a "sexual act" or "sexual contact" that requires registration under SORNA. Accordingly, the district court's denial of defendant's motion to dismiss was proper and the court affirmed the judgment.
The court issued a subsequent related opinion or order on December 4, 2019.
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