Sex Offender Case Law Update (Part II)

Further Update: Well, that didn't take long - the court of appeals issued its revised decision in Worley on July 21, concluding under the supreme court's new definition of "change of address" that Mr. Worley had changed addresses, and thus upholding his conviction for failing to update the sheriff. The court again rejected the argument that "drifters" like Worley have no address, saying that the registry "operates on the premise that everyone does, at all times, have an address of some sort, even if it is a homeless shelter, a location under a bridge or some similar place." In Mr. Worley's case, where it was impossible for him to return to his old residence (because he was evicted) and where there was substantial evidence that he had relocated to a new place (even if he slept outside that place in his van), he had changed addresses for the purposes of G.S. 14-208.11. Update: I just learned that the court of appeals has withdrawn its opinion in State v. Worley in light of the supreme court's decision in Abshire. So, you won't have to rely on my idle speculation about how Mr. Worley might have fared under the new Abshire rule - now we'll find out for real. Coincidentally, I read an article today about an appellate court in Pennsylvania that held that state's registration law did not apply to homeless sex offenders. You can find the article here and the court's opinion here. I'd be surprised by a similar outcome in [...]