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11th Circuit Issues SORNA Opinion

By Corey Rayburnyung

In U.S. v. Dumont, the 11th Circuit held that the defendant's alleged interstate travel during the gap period did not create an Ex Post Facto Clause problem. This has been the majority approach of district courts, so the result is not at all surprising. However, because this opinion was by a federal appellate court, it is obviously more significant. In contrast to the holdings of many district courts, though, the reasoning in the opinion was "odd" at times. From the opinion: This Court recently addressed a timing issue involving a prosecution under SORNA in United States v. Madera, 528 F.3d 852 (11th Cir. 2008), which guides the resolution of Dumont?s appeal. Madera was convicted of a prior sex offense in 2005, and moved from New York to Florida in 2006, all before SORNA?s enactment...continue to full post

Full post as published by Sex Crimes on January 28, 2009 (boomark / email).