State v. Reynolds, ___ N.C. App. ___, 800 S.E.2d 702 (May. 2, 2017)

In this sex offender registration case where the defendant was charged with failing to notify of an address change, there was sufficient evidence that the defendant changed his address. After the defendant registered in 2011, he was incarcerated and then released in 2013. The Supreme Court has clarified that while incarcerated, a registrant’s address is that of the facility or institution in which he is confined and that when he is released from incarceration, his address necessarily changes. The court rejected the defendant’s argument that his incarceration for only a month was not long enough to establish a new address at his place of confinement.