United States v. Brunner, No. 11-2115 (2d Cir. 2013)
Annotate this CaseDefendant appealed his conviction for knowingly failing to register and update his sex offender registration under the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16911 et seq. Defendant's principal argument on appeal was that SORNA was unconstitutional as applied to him because SORNA was enacted in 2006, defendant had already served his full sentence, left the military and severed any connection to the federal government. The court affirmed the judgment of the district court, concluding that, in light of the Supreme Court's decision in United States v. Kebodeaux, Congress possessed the requisite authority through the Military and Necessary and Proper Clauses to hold defendant to SORNA's registration requirements.
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