United States v. Leach, No. 10-1786 (7th Cir. 2011)
Annotate this CaseThe defendant, convicted of child molestation in 1990, failed to register as a sex offender when he was released from prison in 1994, although registration was required by Indiana law. When he was released from prison in 2004, following conviction for theft, he signed an acknowledgement of the requirement and registered. He re-registered when he moved his residence within Indiana, but failed to notify either Indiana or South Carolina authorities when he moved to South Carolina, in violation of the 2006 Sex Offender Registration and Notification Act, 18 U.S.C. 2251. The defendant entered a conditional plea of guilty and was sentenced to 27 months in prison. The Seventh Circuit affirmed, rejecting an argument that the Act violated the Ex Post Facto Clause of the Indiana Constitution. Although parts of the state registration law have been declared invalid, the defendant was required to register in South Carolina. The Act only punishes conduct occurring after its enactment; it simply creates new legal obligations.
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