California transplant wins appeal in sex registry case

3-10-2012 New Mexico:

SANTA FE — Does a convicted sex offender in California have to register with the government if he moves to New Mexico?

The New Mexico Court of Appeals said one such man did not, setting the stage for another courtroom confrontation this month.

Bruce D. Hall, about to turn 65 years old, is the defendant in the middle of this storm over laws and protection of children. Hall is a marked man as a sex offender in California but, so far, not in New Mexico.

Court records show that Hall in 1999 was convicted in California of "annoying or molesting children," a misdemeanor. An assistant attorney general in New Mexico stated in a brief that Hall touched the genitals of three young boys.

Hall moved to Las Cruces, but did not register as a sex offender. This led to his indictment in 2008 for violating New Mexico's Sex Offender Registration and Notification Act.

Hall said that, despite his criminal record, he was not obligated to register as a sex offender. What he did in California was not a sex offense in New Mexico, he argued.

He said he could not be subjected to the registration law and asked that the charge against him be dismissed.

District Judge Douglas Driggers of Doña Ana County rejected Hall's motion. Hall entered a conditional guilty plea, but preserved his right to appeal.

USA v Del Valle-Cruz

4-6-15 Puerto Rico, Oklahoma, Florida:

USA v Del Valle-Cruz

Defendant Carlos Manuel Del Valle-Cruz ("Del Valle-Cruz") was sentenced to twenty-one months in prison and seven years of supervised release after pleading guilty to one count of failing to register as a sex offender.

By our count, this is the third time Del Valle-Cruz has been convicted of failing to register since his 1997 sex offense conviction. As troubling as that is, we note that he has not been charged with any other sex offenses in the intervening eighteen years.

The terms of Del Valle-Cruz's supervised release include a series of special conditions that prohibit him from contact with minors and require him to undergo sex offender treatment — terms that were not imposed as part of his sentence for the underlying sex offense. Moreover, these conditions were imposed in a boilerplate fashion, devoid of any explanation by the district court.

Del Valle-Cruz now seeks to vacate his conviction or, failing that, the aforementioned special conditions. A waiver of appeal bars Del Valle-Cruz's appeal of his conviction, as well as his appeal of most of the special conditions. NOTE: There is a large section within decision that explains this more fully, and includes the Oklahoma case of Starkey.

However, as to his appeal of the conditions that would interfere with his relationship with his son, to avoid a miscarriage of justice, we decline to enforce the waiver and instead vacate those conditions that would prevent Del Valle-Cruz from contact with, or residing with minors.

We will remand for de novo resentencing with respect to the supervised release term, so that the district court can consider the supervised release conditions as a whole and in light of intervening precedent.

Upon remand for further proceedings on the special conditions, we invite the district court to revisit the conditions and to explain their justification in this case.

... ... ...

Conclusion

We dismiss Del Valle-Cruz's appeal of his conviction, as well as the conditions imposing sex offender treatment, and prohibiting working with or volunteering with minors.

We vacate conditions 13 and 15, and we remand to the district court for re-sentencing consistent with this opinion.

The re-sentencing shall be limited to the terms of supervised release, and at that time, given the concerns we have expressed herein, the district court may revisit all of the special conditions. United States v. Francois, 715 F.3d 21, 34 (1st Cir. 2013) ("[P]recedent in this Circuit establishes that `an appellate ruling invalidating a sentence . . . may implicate the trial judge's comprehensive, interdependent imposition of a penalty and thus require resentencing on all counts.'" (quoting United States v. Melvin, 27 F.3d 710, 712 (1st Cir. 1994))). At resentencing the district court should explain its reasons for the imposition of conditions and provide factual findings supported by the record.

Supreme Court: Stallworth Does Not Have to Register as a Sex Offender

4-16-15 Mississippi:

The Mississippi Supreme Court ruled today that a Jackson pastor, who was convicted of a sex crime in another state but had the conviction expunged, does not have to register as a sex offender in Mississippi.

Jeffrey A. Stallworth pleaded guilty to a misdemeanor sexual assault of a woman in Maryland in 2002, requiring him to register as a sex offender.

Later, in 2010, a Maryland judge expunged the conviction. Stallworth argued that he should not have to appear on the Mississippi sex offender registry. The Mississippi attorney general's office, which is representing the state, disagreed with Stallworth's argument.

In a split decision, the state supreme court agreed with Stallworth's interpretation.

Michigan v Juntikka

4-21-15 Michigan:

Michigan v Juntikka

At issue in this case is whether a trial court properly imposed a $100 probation enhancement fee upon defendant under MCL 771.3. Because we conclude that MCL 771.3(2)(d) does not independently authorize trial courts to impose any assessment, and because we conclude that the probation enhancement fee was not statutorily authorized as a cost specifically incurred in defendant’s case, we vacate the portion of the court’s order imposing the probation enhancement fee and remand for further proceedings.

On January 23, 2013, defendant pleaded guilty to one count of failing to register as a sex offender, MCL 28.729. The trial court sentenced defendant to a five-year probationary term and
12 months in the county jail. The court additionally ordered defendant to pay several financial
charges, including a $100 probation enhancement fee.

On August 6, 2013, defendant filed a motion for resentencing, contending, among other things, that the $100 probation enhancement fee was improper because it was an unauthorized assessment. The court denied defendant’s motion, explaining that the probation enhancement fee covered items including “gloves so that the probation agents may test bodily fluids more safely” and “cell phones so that [agents] can quickly respond to issues that may arise.” The trial court concluded that because defendant was on probation, the fee rendered him a potential benefit and so fell within the ambit of MCL 771.3(2)(d).

Maine v Reynolds

5-7-15 Maine:

Maine v Reynolds

Ronnie L. Reynolds appeals from a judgment of conviction entered by the Superior Court (Washington County, R. Murray, J.) after a jury found Reynolds guilty of his second offense of failing to comply with the Sex Offender Registration and Notification Act of 1999 (Class C), 34-A M.R.S. § 11227(2) (2014).

Reynolds is, by law, a lifetime registrant; however, he asserts that he was led to believe that a 2004 amendment to SORNA changed his classification from a lifetime registrant to a ten-year registrant.

He contends that the court erred in excluding relevant evidence of a letter from the Department of Public Safety, State Bureau of Identification that caused him to believe that he was no longer required to register. See 34-A M.R.S. § 11227(6) (2014).

We agree that the court erred in excluding the letter. We vacate the judgment and remand for further proceedings.

... ... ...

In short, had the letter been admitted in evidence and had Reynolds offered testimony about the letter, it would have been for a jury to determine the reasonableness of (1) Reynolds’s belief that the letter reclassified him as a ten-year registrant and (2) his belief that the ten-year registration period had expired, thus amounting to just cause for failing to register.

To the extent that the court determined that Reynolds’s purported reliance on the letter was not believable, the court made a credibility determination that should have been made by the jury. See Allen, 2006 ME 20, ¶ 26, 892 A.2d 447. The court’s exclusion of the letter as irrelevant was clearly erroneous.

Don’t Have $35? How About an Arrest for Failure to Register as a Sex Offender?

April 2015 Florida:

by The Law Office of John Guidry II

Forgive me for stating the obvious, but a criminal record will hurt your employment opportunities. A petit theft charge, for example, will limit job opportunities in retail stores because most retail stores suffer the majority of their losses at the hands of their employees–so these stores prefer to hire someone with a record of driving on a suspended license or marijuana possession, rather than theft.

And, while theft charges can put a dent in things, being a sex offender absolutely crushes any hope of ever being employed again. Period. Not a dishwasher (not that there’s anything wrong with that). Not flipping burgers, rolling burritos–nothing. Not only can sex offenders not find employment (double negative? Maybe not), good luck finding a place to live that isn’t within a 1000 feet of a school or playground. I’ve seen city’s set up playgrounds just to drive out sex offenders–so much for liberty and freedom to travel.

It should come as no surprise that the bleak employment prospects of sex offenders also translate into a life of living under bridges, and having no money (redundant, I know). To add insult to injury, when a sex offender moves from sleeping under one bridge to sleeping under another bridge, this change of address requires government intervention. You anti-government folks (me?) should be jumping up and down when the government tacks on requirements to a citizens’ movements once they’ve completed their prison time and probation.

Leonard Swanagan

8-14-2012 Georgia:

In July 2008, sheriff’s deputies in Cobb County, Georgia arrested 54-year-old Leonard Swanagan on charges of failing to register as a convicted sex offender and living within 1,000 feet of a public swimming pool.

Swanagan contended that he was not required to register, but in July 2011, he was convicted in Cobb County Superior Court after the prosecution produced records showing he had been convicted of a misdemeanor sex offense in Ohio in 1994. The records also showed that when he moved to Illinois in 1996, he had registered as a sex offender there. Swanagan was sentenced to 10 years in prison, but all but a year was suspended.

In 2012, Swanagan reached out to the media, and Jeff Chirico, a reporter for CBS television news in Atlanta, began investigating the case. Chirico discovered that under existing sex offender registry laws, Swanagan’s name should have been removed from sex offender registry lists in 2004.

After the news report aired, the prosecution investigated the claim and determined that Swanagan was not required to register as a sex offender in Georgia. Swanagan obtained a new defense attorney who filed a motion to vacate the conviction and to dismiss the case.

On August 6, 2012, Swanagan was released from custody and on August 14, at the request of the defense and the prosecution, his conviction was vacated and the charges were dismissed.

In 2014, Swanagan filed a federal civil rights lawsuit in Atlanta. ..Source.. by Maurice Possley

Corey Eason

10-25-2005 Illinois:

When 23-year-old Corey Eason, a small-time central Illinois drug dealer, was paroled from prison for a cocaine dealing conviction in 2002, he was mistakenly classified as a sex offender even though he had never been accused, arrested or convicted of any sex-related offense. As a result, Eason (who was unaware of this error) was listed on Illinois’ sex offender registry, and had his picture posted on the Internet.

Three years later, in March 2005, when Eason was arrested in Bloomington and charged with assault and possession of a controlled substance, his name was found on the sex offender registry. As a result, he was charged with three counts of failing to report a change of address as required by the Illinois Sex Offender Registration Act, and convicted at a bench trial.

In September 2005, at the request of Eason’s attorney, the McLean County Probation Department contacted the Illinois State Police, who maintain the sex offender website, and they looked into Eason’s case. They could not explain why Eason was prosecuted since it was evident from his criminal record, which was available to both prosecutors and defense counsel, that he had never been convicted of a sex offense.

The McLean County prosecutors were also notified of the mistake, and, at a hearing on October 25, 2005, they acknowledged the error. McLean County Circuit Court Judge Ronald Dozier vacated the convictions, saying, “I’m glad we got this straightened out before it got too much further down the line.” Eason received probation on the assault and drug possession charges for which he had been arrested in March, 2005.

Eason’s plan to pursue a civil suit over his ordeal never materialized. In April 2011, he was charged with possession of cocaine with intent to distribute. ..Source.. by Center on Wrongful Convictions

Longino Acero

March 2006 California:

In July 1978, Longino Acero entered a no contest plea to a charge of lewd conduct with an adult woman, which did not require registration as a sex offender.

But because of a clerical error, Acero’s conviction was recorded as child molestation, a crime that did require registration.

From 1994 until 2004, Acero was arrested three separate times and sentenced to prison terms ranging from four months to more than two years, each time on a charge of failing to register as a sex offender. He was publicly listed as a high-risk sex offender.

Although on each occasion Acero told his attorneys that he had never committed a crime against a minor, the attorneys failed to check the court file, and repeatedly advised him to plead guilty.

In September 2005, Acero received a letter from the San Jose Police Department informing him that his original misdemeanor conviction had been recorded incorrectly and he should never have been required to register as a sex offender.

After retaining a new attorney, Acero petitioned the Santa Clara County Superior Court to overturn his convictions for failure to register.

The court granted his petition in March 2006, his guilty pleas were withdrawn, and the charges were dismissed. Acero filed a claim for compensation from the state of California, but it was denied. ..Source.. by Maurice Possley

Simon Angel Rivera

1-26-2005 Texas:

In 1992, Simon Angel Rivera was convicted as a juvenile of sexually assaulting a child when he was a 14 years old. On September 15, 2002, Rivera, 24, was arrested in Austin, Texas on charges of failing to register as a sex offender. On December 16, 2002, Rivera pleaded guilty in Travis County Criminal District Court and was sentenced to two years in prison.

After he was released on February 20, 2004, he filed a state petition for a writ of habeas corpus seeking to set aside his conviction, contending that his attorney had provided inadequate legal defense.

Rivera argued that his lawyer had advised him to plead guilty based on an incorrect understanding of the facts and law applicable to his case. Rivera claimed that at the time when he was charged with failing to register as a sex offender he was no longer required to do so because his juvenile status at the time of his conviction. The law did not require defendants convicted as juveniles to register after the age of 21.

After a hearing in the trial court, the prosecution agreed that Rivera was correct and recommended the writ be granted, and it was.

On January 26, 2005, the Texas Court of Criminal Appeals upheld the granting of the writ and vacated Rivera’s conviction. The charges were dismissed by the Travis County District Attorney’s Office on March 11, 2005.

In September 2007, the state of Texas awarded Rivera $40,000 in compensation for his wrongful imprisonment. ..Source.. by Maurice Possley

Darrell Wayne Bivens, J

3-27-2013 Texas:

In 1994, when Darrell Wayne Bivens, Jr. was 16, he was charged with committing an indecent act with a child in Collin County, Texas. He was charged as an adult and after a period of deferred adjudication, was sentenced to two years in prison.

On April 19, 2012, Bivens was arrested in Collin County on a charge of failing to register as a sex offender. He pled guilty on January 10, 2013, and was sentenced to three years in prison.

Not long after, the Collin County District Attorney’s office discovered that because Bivens was under the age of 17 at the time of the original sex offense, his crime was not considered a sexually violent offense and, therefore, his duty to register as a sex offender had expired in 2008. Bivens had been charged with failing to register because he was misclassified as an adult.

On February 13, 2013, about a month after Bivens had pled guilty and had been sentenced, the Collin County District Attorney’s Office went back to court to seek to vacate the guilty plea and dismiss the case. A judge vacated the conviction and the case was sent to the Texas Court of Criminal Appeals. Bivens was released on bond.

On March 27, 2013, the Texas Court of Criminal Appeals agreed with the lower court and vacated the conviction. That same day, the prosecution dismissed the case. ..Source.. by Maurice Possley

Glen Nobles

2-27-2015 Texas:

On March 8, 2013, 52-year-old Glen Nobles was accused of failing to register as a sex offender based on a 1989 conviction for attempted sexual assault. On the advice of his defense attorney, Nobles pled guilty and was sentenced to 10 years in prison.

In 1989, Nobles had been convicted of attempted sexual assault and sentenced to probation. In 1995, he was found to have violated that probation and was sent to prison for four years. He was released but soon sent back to prison on another probation violation. Ultimately, he was released on November 24, 2001.

While in prison after pleading guilty in 2013, Nobles began investigating the sex offender registry laws in Texas and learned that the obligation to register lasts for 10 years and that in view of his history of probation violations and imprisonments, his obligation to register expired in November 2011—15 months before he was accused of failing to register as a sex offender.

In April 2014, Nobles filed a state-court petition for a writ of habeas corpus seeking to vacate his guilty plea. The Sabine County District Attorney’s Office investigated and agreed that in March 2013, when was he was charged with failing to register, Nobles was no longer required to do so.

The prosecution joined with Nobles’ defense attorney in requesting that the conviction be vacated. After the trial court recommended the conviction be set aside, the Texas Court of Criminal Appeals, on January 14, 2015, vacated Nobles’ conviction saying that “the period during which (Nobles) was required to register as a sex-offender expired on November 24, 2011. (Nobles) was no longer required to register as a sex offender after this date.”

On February 27, 2015, a Sabine County Criminal District Judge signed an order presented by the prosecution dismissing the charge. ..Source.. by Maurice Possley

USA v Medina

3-4-2015 Puerto Rico:

USA v Medina

Moisés Medina failed to register as a sex offender when he moved to Puerto Rico in May of 2012, even though he had been convicted of a state sex offense four years earlier. As a result, Medina was arrested for violating the Sex Offender Notification and Registration Act, also known as SORNA, 18 U.S.C. § 2250. He then pled guilty and was sentenced to a thirty month prison term, to be followed by a twenty-year term of supervised release.

The supervised release portion of the sentence included various conditions that Medina must follow or face returning to prison. Medina now challenges two of those conditions as well the
length of the supervised release term. One of the two conditions restricts Medina from accessing or possessing a wide range of sexually stimulating material. The other requires Medina to submit to penile plethysmograph testing -- a particularly intrusive procedure -- if the sex offender treatment program in which he must participate as a condition of his supervised release chooses to use such testing.

We hold that the District Court erred in setting the length of the supervised release term. We further hold that the District Court inadequately justified the imposition of the supervised release conditions that Medina challenges. We therefore vacate Medina's supervised release sentence term and the conditions challenged on this appeal, and remand for re-sentencing.

United States v Rojas

Make absolutely certain EVERTHING is written into a plea agreement before giving up right to appeal!

3-11-2015 Puerto Rico:

United States v Rojas

Pursuant to a plea agreement, Defendant pleaded guilty to failing to register as a sex offender, as required by the Sex Offender Registration and Notification Act. The district court sentenced Defendant to one year in prison.

The court also sentenced Defendant to ten years of supervised release and imposed several conditions of supervised release. Defendant appealed, challenging three of those conditions.

The First Circuit dismissed the appeal without reaching the substance of the appeal because Defendant agreed knowingly and voluntarily to accept the the “waiver of appeal” provision in his plea agreement, and this appeal fell within the scope of that waiver.

USA -v- Fernandez

1-15-2015 Louisiana:

USA -v- Fernandez

In 2013, Fernando Fernandez was convicted, pursuant to his guilty plea, of failing to register as a sex offender, in violation of 18 U.S.C. § 2250(a). He challenges a life-term special condition of supervised release, requiring him to “install [computer] filtering software . . . block[ing]/monitor[ing] access to sexually oriented websites” for “any computer he possesses or uses”.

At issue is whether the court abused its discretion by imposing the software-installation special condition in the light of, inter alia, Fernandez’ neither using a computer nor the Internet in committing either his current offense (failing to register as a sex offender) or his underlying sex offense (sexual assault of a child).

....

In the light of the facts at hand, the district court abused its discretion in imposing the software-installation special condition provision at issue, when, inter alia, neither his failure-to-register offense nor his criminal history has any connection to computer use or the Internet.

Similar to Tang, the special condition imposed in this instance is related neither to the nature and circumstances of Fernandez’ offense (failing to register as a sex offender) nor his criminal history and characteristics.

Along that line, the district court’s reason for justifying the special condition is not sufficiently tied to the facts. As noted, for justifying its imposition, the court stated: “‘Failure to register’ means he’s a sex offender in the past. Ease of access through the Internet”.

In the absence of evidence to the contrary, the court’s general concerns about recidivism or that Fernandez would use a computer to perpetrate future sex-crimes are insufficient to justify the imposition of an otherwise unrelated software-installation special condition.

For the foregoing reasons, the special condition requiring software installation is VACATED; this matter is REMANDED for entry of the corrected judgment.

USA -v- Collins

12-9-2014 West Virginia:

USA -v- Collins

Dwaine Allen Collins was convicted of knowingly failing to register as a sex offender under the Sex Offender Registration and Notification Act (SORNA). The district court sentenced Collins to 30 months’ imprisonment and ten years of supervised release. On this direct appeal, Collins contests his conviction primarily on the grounds that the government failed to prove an essential element of a SORNA violation: that he knew he had an obligation to register.

In support, he points to comments made by a state court judge in a separate proceeding, which in Collins’s view suggest that his obligation to register had expired. We agree with the district court, however, that the state judge appeared to be giving advice rather than a binding legal opinion. Moreover, there is substantial evidence in the record to support the district court’s conclusion that Collins knowingly avoided an obligation to register as a sex offender. We thus find Collins’s claim unpersuasive and affirm his conviction.

Collins also appeals his sentence. We find his 30-month term of imprisonment, which is within the applicable Guidelines range, to be reasonable and thus affirm the district court’s sentence in that respect. As to the term of supervised release, however, the United States Sentencing Commission recently issued a clarifying amendment stating that a failure to register under SORNA is not a “sex offense” for the purposes of the Guidelines. Consequently, we vacate the supervised release portion of Collins’s sentence and remand for further proceedings.

... ... ... ...

For the reasons provided above, we affirm Collins’s conviction and his term of imprisonment, and remand for further proceedings consistent with this opinion as to his term of supervised release.

Johnson v Indiana

11-24-2014 Indiana:

Johnson -v- Indiana

Michael E. Johnson (“Johnson”) was convicted of Failure to Register as a Sex Offender, as a Class C felony. He now appeals, contending that the State failed to adduce sufficient evidence to support his conviction; the State concedes a failure of proof as to Johnson’s duty to register.

Facts and Procedural History
On November 17, 1994, when he was eighteen years old, Johnson was convicted of Rape, as a Class B felony, for an offense he committed while he was seventeen years old.

On January 6, 2012, while investigating other matters, police attempted to make contact with Johnson at several addresses in Indianapolis. Among these was an address he had provided on a registration form in 2011. Police officers visited this location, but Johnson did not reside at that address. The occupant of the home did not know Johnson and was unable to provide police with any information as to Johnson’s whereabouts.

Police eventually located Johnson at another location. Johnson was arrested.

On January 10, 2012, Johnson was charged with two counts of Failure to Register as a Sex Offender, as Class D felonies enhanced to Class C felonies as a result of prior convictions, and with one count of Failure of a Sex or Violent Offender to Possess Identification, as a Class A misdemeanor.

...

Conclusion:

Accordingly, as Johnson’s brief notes, his age at the time he committed Rape is dispositive. Based upon the evidence submitted at trial, Johnson was not under any duty to register as a sex offender, and we accordingly reverse the judgment of the trial court and remand with instructions to vacate Johnson’s conviction in this matter.

Reversed and remanded.

COURT: Sex offender doesn't have to register

9-22-2014 Indiana:

Paille -v- Indiana

MUNCIE – A Muncie man convicted of sex crimes in Florida does not have to register locally as a sex offender, the Indiana Court of Appeals has ruled.

In a 3-0 ruling, the appeals court also ordered local authorities to dismiss two criminal charges pending against 44-year-old Michael Troy Paille that stemmed from his failure to register with the Delaware County Sheriff's Office.

In this month's decision, Judge Cale Bradford acknowledged that when Paille most recently was released from a Florida prison, in 2011, he was "required to register in Florida as a sex offender for at least 25 years."

However, because Paille's Florida crimes and convictions predated the 1994 enactment of Indiana's Sex Offender Registry Act, he is not required to register here, Bradford wrote. He noted a 2009 ruling by the Indiana Supreme Court that "the application of INSORA to crimes committed before INSORA's 1994 enactment was unconstitutional."

USA -v- Brewer

9-10-2014 Arkansas:

USA -v- Brewer

Defendant appealed his conviction for failing to register as a sex offender under 18 U.S.C. 2250(a). In 2006, Congress enacted the Sex Offender Registration Notification Act (SORNA), 42 U.S.C. 16901-16991. In 2007, the Attorney General promulgated an Interim Rule that made registration requirements applicable to all pre-Act offenders without establishing a period for pre-promulgation notice and comment and bypassed the 30-day publication requirement.

Defendant argued that the Attorney General lacked good cause and thereby violated the Administrative Procedures Act (APA), 5 U.S.C. 551 et seq. The court joined the Third, Fifth, Sixth, and Ninth Circuits and found that the Attorney General's stated reasons for finding good cause to bypass the 30-day advance-publication and notice-and-comment requirements were insufficient.

Because the Attorney General lacked good cause to waive the procedural requirements of notice and comment when promulgating the Interim Rule, and this procedural error prejudiced defendant, SORNA did not apply to defendant in 2007. Therefore, his conviction for failing to register is invalid.

The court did not address defendant's remaining argument that SORNA violates the nondelegation doctrine.

The court reversed and remanded for the district court to vacate the conviction.

Edmond Sex Offender Cites 'Starkey' in Failure to Register Arrest

8-1-2014 Oklahoma:

Edmond police responding to a public intoxication call discovered a transient sex offender living within 2000 feet of a school. Police say Shaun Anthony Head, 38, had failed to register as a sex offender and was staying at an apartment complex near Edmond Memorial High School in violation of sex offender residency requirements.

When an officer asked Head why he had not registered as required, the suspect responded that he no longer had to register as a result of the state Supreme Court's ruling in Starkey v. Oklahoma Department of Corrections.

Unfortunately for Head, although the Starkey decision will allow thousands of convicted sex offenders to come off of the Oklahoma Sex Offender Registry, the decision does not take full effect until the DOC has had time to review a list of more than 10,000 registrants who may be eligible for removal. Since the Supreme Court's order on June 25, 2013, the agency has whittled the list down to just under one thousand registrants remaining.

So what is the Starkey case that will allow some convicted sex offenders to be removed from the state sex offender registry?