Reynolds v. United States

The Sex Offender Registration Act does not require offenders convicted before the Act was passed to register until the Attorney General has validly specified that the registration provisions apply to them.

The Sex Offender Registration and Notification Act (Act) requires convicted sex offenders to provide their contact information and to keep that information updated with state and federal sex offender registries. The Act grants power to the Attorney General to specify the applicability of the registration requirements to sex-offenders who were convicted before the Act was passed. Billy Joe Reynolds was charged with violating the Act, after he failed to update his contact information, in the United States District Court for the Western District of Pennsylvania. He moved to dismiss arguing that the Interim Rule set by the Attorney General was invalid. The District Court rejected Reynold’s argument. The Court of Appeals upheld the decision without reaching the merits noting that the Act required Reynolds to register at the time it was passed regardless of any interim rule set forth by the Attorney General.

The Supreme Court reversed, holding that the Act’s registration requirements did not require pre-Act offenders to register before the Attorney General validly specified the applicability of the Act’s registration provisions. The Court came to its decision through a plain reading of the text of the Act. Under such a reading, the provision granting the Attorney General the authority to determine the applicability of registration requirements applied to the specific class of pre-Act offenders. The Court also rejected the Government’s argument that such a reading conflicted with the Act’s purpose of establishing a registration system that applied to pre-Act offenders.