United States v. Anderson, No. 14-1165 (8th Cir. 2014)
Annotate this CaseDefendant pled guilty to failing to register as a sex offender under the Sex Offender Registration and Notification Act (SORNA), 18 U.S.C. 2250(a)(2)(B), and appealed the denial of his motion to dismiss the indictment. The court concluded that, while doubting the constitutionality of 42 U.S.C. 16913 under the Commerce Clause alone, the enabling necessary and proper clause reveals the statute is constitutionally authorized where the registration requirements of section 16913 are part of the constitutional power Congress has to punish sex offenders who cross state lines. The registration requirement of SORNA is a valid exercise of the Commerce Clause and defendant has not clearly demonstrated the lack of constitutional authority for Congress to enact section 16913(a). The court also concluded that even if section 2250(a)(2)(B) were distinguishable from Gonzales v. Raich, and thus not constitutional under the third prong of United States v. Lopez, SORNA would still remain valid under the first two interstate commerce jurisdictional prongs. The enforcement of the registration requirement is a valid exercise of the Commerce Clause, and defendant has not clearly demonstrated the lack of constitutional authority for Congress to enact section 2250(a)(2)(B). Accordingly, the court affirmed the conviction.
Court Description: Criminal case - Criminal law. Even if the constitutionality of 42 U.S.C. Sec. 16913 is doubtful under the Commerce Clause alone, the enabling necessary and proper clause reveals the statute is constitutionally authorized because the registration requirements of the statute are part of the constitutional power of Congress to punish sex offenders who cross state lines; enforcement of the registration requirement is a valid exercise of the Commerce Clause and defendant has not clearly demonstrated the lack of constitutional authority for Congress to enact 18 U.S.C. Sec. 2250(a)(2)(B).
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