Meador v. Branson , No. 11-3088 (8th Cir. 2012)
Annotate this CaseIn 1994, Defendant was convicted of sex crimes in Kentucky. When Defendant moved to North Dakota in 2008, he was required to register as a sex offender. Because Defendant did not have a residence for a short while, he did not properly register. North Dakota then filed a criminal complaint against Defendant, charging him with failure to comply with registration requirements. The trial court convicted Defendant as charged. Defendant appealed, arguing that the state district court erred in interpreting N.D. Cent. Code 12.1-32-15(7) as requiring him to register within three days even though he had not obtained an address. The Supreme Court affirmed. Defendant subsequently filed a petition for relief under the Antiterrorism and Effective Death Penalty Act (AEDPA) in federal court that included an amended claim arguing he was denied due process of law by the state's attorney interpreting the statute to include persons who have no residence to register. The district court granted the certificate of appealability on the amended claim. The Eighth Circuit Court of Appeals affirmed, holding that, under the AEDPA and Bouie v. City of Columbia, the state court's interpretation of its own statute was not an unforeseeable and retroactive expansion of statutory language.
Court Description: Prisoner case - Habeas. District court did not err in determining that the North Dakota Supreme Court's interpretation of the state's sex offender registration statute to apply to sex offenders even when they have no permanent residential or mailing address was not an unforseen and retroactive expansion of statutory language such that it resulted in a decision that was contrary to, or involved an unreasonable application of clearly established federal law as determined by the Supreme Court of the United States.
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