Louisiana v. Clark
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The state charged defendant by bill of information with failing to maintain his registration as a convicted sex offender by failing to appear for his quarterly registration with the Jefferson Parish Sheriff’s Office. Defendant filed a motion to quash the bill of information on grounds that he had fully satisfied any registration duty he may have had before establishing residence in Louisiana and that he was therefore under no legal obligation to register as a sex offender in the state. Defendant argued, and the trial court agreed, that he had satisfied his duty to register in Louisiana by operation of law under the existing 10-year period by December 2005, and that he therefore had no duty to register when he came to Louisiana in March 2009. The trial court rejected the state’s argument that the registration period, whether measured by 10 years or 25 years, had not lapsed because it had not begun until defendant moved to this state in 2009. The court of appeal agreed with defendant in a split panel decision that his "duty to register expired by operation of law in December 2005, 10 years after his release from custody and a little over two years prior to the effective date of the [2007] amendment." The Supreme Court after its review disagreed with the trial and appellate courts and reversed: "defendant was not 'a person required to register' in Louisiana until he established residence . . .under former law, as under current law, defendant’s duty to register and maintain his registration for a period of 10 years did not terminate in 2005 because, as the state argue[d], it did not begin until 2009, when he established residency in this state, and he had not extinguished his obligation under the former law, much less under the current expanded registration periods, before his arrest in 2010."
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