Silas Bernard Peterson v. United States
In Descamps v. United States, 570 U.S. 254 (2013), this Court held that when a federal sentencing statute (the Armed Career Criminal Act) referred to a prior "conviction" district courts should use a categorical analysis to determine if a state conviction is a qualifying offense. Here, the federal sex registration statue, SORNA, refers to "convictions" and offenses involving "conduct that by its nature is a sex offense." The district court decided that it could use a noncategorical, circumstance specific analysis to determine if the petitioner's state court conviction subjected him to sex offender registration requirements under SORNA.
The question presented is: did the district court err when it used a circumstance specific analysis to determine that the petitioner's state conviction subjected him to sex registration requirements under SORNA?
QP: Did the district court err when it used a circumstance-specific analysis to determine that the petitioner's state conviction subjected him to sex registration requirements under SORNA?