USA v. Navarro, No. 19-50662 (5th Cir. 2022)
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In 1998, Defendant pleaded guilty of attempted sexual assault of a minor in Colorado. In 2013, Defendant moved to Texas. In 2019, law enforcement discovered that Defendant was not registered as a sex offender in Texas and arrested him. Defendant pleaded guilty of failing to register as required by the federal Sex Offender Registration and Notification Act (“SORNA”), a crime under 18 U.S.C. Section 2250(a). He completed his term of imprisonment but violated the terms of his supervised release twice and is serving an 11-month revocation sentence. Defendant claims that his guilty plea for failing to register as a sex offender was insufficient as a matter of law because in 2019 he did not have an obligation to register as a sex offender.
The Fifth Circuit agreed with Defendant and vacated the conviction. The court explained that it is hard to deny that Defendant would not have pleaded guilty if he had correctly understood the tier of his predicate sex offense. Similarly, the district court would likely not have accepted the guilty plea if it had known Defendant had failed to satisfy the first element of the crime Further, affirming Defendant’s conviction would undermine the integrity of judicial proceedings by permitting the continued punishment of a man who is not guilty of the crime charged.
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