United States v. Stevenson, No. 10-1043 (6th Cir. 2012)Annotate this Case
Defendants, convicted of state-law sex offenses requiring them to register before the enactment of the federal Sex Offender Registration and Notification Act, 42 U.S.C. 16901, were indicted for traveling in interstate commerce in 2009 and knowingly failing to update their registrations, 18 U.S.C. 2250(a). The district court dismissed each of their indictments, holding that SORNA had not yet been made retroactively applicable to the defendants. The Sixth Circuit reversed, holding that SORNA became retroactively effective on August 1, 2008, the effective date of the SMART guidelines, promulgated by the Attorney General.