United States v. Billiot, No. 14-2724 (8th Cir. 2015)
Annotate this CaseBilliot was convicted in Louisiana state court on three counts of aggravated incest in 1996, and on one count of aggravated incest in 1997. He was released from state custody in 2000. At the time of Billiot’s convictions, Louisiana law required convicted sex offenders to register for 10 years after release from imprisonment. La. Stat. 15:544. Amendments to Louisiana law now impose lifetime registration and notification requirements on certain offenders. Billiot initially complied with the registration law, but in 2012, he moved to Arkansas. Billiot admits he knew he had a duty to register, but he failed to do so after moving. Billiot pled guilty to violation of the Sex Offender Registration and Notification Act, 18 U.S.C. 2250, but asserted that in 2000, Louisiana officials told him he had to register for 10 years. Only later did an employee of the Louisiana sex offender registry tell him that he must register for life. The district court held that “extension of Billiot’s registration obligation … while he was subject to the original obligation,” did not present a “federal constitutional problem.” The Eighth Circuit affirmed, rejecting an Ex Post Facto Clause argument and a challenge to a special condition of supervised release, requiring sex-offender treatment.
Court Description: Gritzner, Author, with Wollman and Gruender, Circuit Judges] Criminal case - Criminal law and sentencing. Ex post facto challenge to SORNA rejected under Circuit precedents; challenge to special conditions of supervised release was precluded by defendant's plea agreement and appeal waiver, see U.S. v. Andis, 333 F.3d 886 (8th Cir. 2003)(en banc)
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.