United States v. Schofield

Defendant pleaded guilty to one count of attempted transfer of obscene material to a minor. On appeal, defendant challenged the district court's requirement that he register as a sex offender after his release from prison. The court applied the plain language of the Sex Offender Registration and Notification Act (SORNA), 18 U.S.C. 1470, because the SORNA residual clause is neither ambiguous nor vague. Applying either the noncategorical or categorical approach to defendant’s attempted transfer of obscene material to a minor, his offense of conviction falls within the SORNA residual clause, and he must therefore register as a sex offender. The court affirmed the judgment. View "United States v. Schofield" on Justia Law