Missouri Court of Appeals,Western District.
Summary of case is John Doe v. James F. Keathley, decided by the Missouri Court of Appeals, Western District, in 2011.
Here is a summary of the outcome and the court’s reasoning:
Case Outcome
The Missouri Court of Appeals reversed the judgment of the circuit court. This means the court ruled against John Doe, who was seeking to be free from sex offender registration requirements.
Holding and Reasoning
- Issue: The central question was whether John Doe was considered “convicted of a sex offense” under the federal Sex Offender Registration and Notification Act (SORNA), despite having received a Suspended Imposition of Sentence (SIS) in Missouri state court. Under Missouri law, an SIS is generally not considered a conviction for some purposes.
- Federal Law Controls: The Court held that the meaning of the term “convicted” in a federal statute like SORNA is a matter of federal law, not state law. This is necessary to ensure a uniform national system for sex offender registration, which was Congress’s intent in enacting SORNA.
- SIS is a Federal “Conviction”: Citing precedent from the U.S. Supreme Court (specifically Dickerson v. New Banner Institute, Inc.), the court found that under federal law, a plea of guilty followed by probation and a suspended imposition of sentence does constitute a “conviction.”
- The court reasoned that a person cannot be placed on probation unless the court deems them guilty of a crime.
- The federal statute (SORNA) applies to anyone “convicted” of a sex offense, regardless of the punishment actually imposed.
- Conclusion: Because Doe’s guilty plea and suspended imposition of sentence in 1992 met the definition of a “conviction” under federal law (SORNA), he was therefore required to register as a sex offender under the federal act.