State v. Brunning
Annotate this CaseAt issue in this case was Appellant’s failure to provide notice of a change of residence address. Appellant was a sex offender, originally classified under Megan's Law, who was indicted for violating the address-notification requirements of the Adam Walsh Act (AWA) before State v. Bodyke was decided. Bodyke made the requirements of the AWA inapplicable to offenders such as Appellant. In addition, Appellant was charged with tampering with records because he filed an address-verification form with false information. The form was filed with a sheriff under the mistaken belief that it was required. Appellant pleaded guilty to the charges. The court of appeals reversed, reasoning that the charges against Appellant were based upon violations of the AWA, which, pursuant to Bodyke, did not apply to Appellant. The Supreme Court reversed, holding (1) Bodyke does not require the vacation of convictions where the conduct at issue was a violation of Ohio Rev. Code 2950.05 both as it exists under the AWA and as it existed under Megan's law; and (2) regardless of whether a person has a duty to file an address-verification form, filing a form containing false information with the intent to defraud can be a violation of Ohio Rev. Code 2913.42.
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