United States v. Manning, No. 14-2829 (8th Cir. 2015)
Annotate this CaseManning, who had a 1997 Texas sexual assault conviction, was arrested in El Dorado, Arkansas, and charged with failing to register as a sex offender in violation of 18 U.S.C. 2250, the Sex Offender Registration and Notification Act (SORNA). Manning entered a conditional guilty plea and appealed the denial of his motion to dismiss, raising “frequently-litigated” constitutional and statutory issues. The Eighth Circuit affirmed, rejecting Manning’s argument that SORNA did not clarify whether its registration requirements apply to convictions prior to its enactment. The court rejected specific arguments that delegating to the Attorney General the legislative power to determine the individuals to whom SORNA applies violates the constitutional nondelgation doctrine that is “rooted in the principle of separation of powers” and that SORNA violates the Commerce Clause.
Court Description: Loken, Author, with Smith and Colloton, Circuit Judges] Criminal case - Criminal law. Defendant's constitutional challenges to SORNA have been rejected by this court and are foreclosed by Eighth Circuit precedent; the court joins other circuits in rejecting defendant's claim that the SMART Guidelines were not a proper exercise of the Attorney General's authority under 42 U.S.C. Sec. 16913(d) to specify whether SORNA's registration requirements apply to pre-Act offenders.
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