Thursday, January 31, 2013

Reynolds v. United States case brief

Reynolds v. United States
132 S. Ct. 975

PROCEDURAL HISTORY: Defendant was indicted for failing to comply with the registration requirements of the federal Sex Offender Registration and Notification Act (Act), 42 U.S.C.S. § 16901 et seq., but the defendant claimed that the requirements did not apply to the defendant. Upon the grant of a writ of certiorari, the defendant appealed the judgment of the U.S. Court of Appeals for the Third Circuit which affirmed a denial of a motion to dismiss the indictment.

FACTS: The defendant contended that he was convicted and served his sentence prior to enactment of the Act, that the Act's registration requirements thus did not apply to the defendant until the U.S. Attorney General (AG) determined the applicability of the Act to pre-Act offenders, and that the AG's rule applying the Act to pre-Act offenders was invalid. The U.S. Supreme Court held that the Act did not require the defendant, as a pre-Act offender, to register before the AG validly specified that the Act's registration provisions applied to the defendant. The Act expressly granted the AG the authority to specify the applicability of the registration requirements to sex offenders convicted before the enactment of the Act, and such language was more naturally read to confer authority to apply the Act, not authority to make exceptions to applicability. Further, it was reasonable to conclude that Congress granted the authority to the AG to examine pre-Act offender problems and to apply the new requirements accordingly and to fill potential lacunae in a manner consistent with basic criminal law principles, and any delay in implementing the Act would not be unduly lengthy.

OUTCOME: The judgment affirming the denial of the defendant's motion to dismiss the indictment was reversed, and the case was remanded for further proceedings. 7-2 Decision; 1 Dissent.

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