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YTD 2025: Courts Narrow Relief, States Tinker with Tiers, Zones Expand

Week 1 (Aug 30, 2025)

This week at a glanceHighlightsStates (A→W)Court decisionsMediaWatchlist

🗓️ This Week at a Glance

  • 🏛️ Federal: The U.S. Sentencing Commission adopted supervised-release changes (effective Nov 1, 2025) shaping internet/device rules and responses to violations. USSC amendments · Federal Register notice
  • 🗺️ States: PA (Act 22) adds youth-sports/nonprofit abuse to Tier II; TN centralizes classifications; AR expands “no-go” zones and adds juvenile fee waiver; FL passed a broad update effective Oct 1; UT recodified registry statutes; WV adjusted administrative fees.
  • ⚖️ Cases: OK upheld retroactive park-distance rule; MO upheld lifetime GPS in an as-applied challenge; 10th Cir okayed strict device/internet limits; 6th Cir said TN injunctions must target specific provisions.
  • 📣 Action: Florida CS/HB 1351 implementation ahead of Oct 1; track Michigan SB 424 hearings; watch WA SB 5312 re-intro in 2026.
Why this matters: Policy moves fast; we translate the legalese and link official sources so you can verify and act.

⭐ Highlights

🏛️ U.S. Sentencing Commission — Supervised-Release Changes

In plain terms: New guidance tells judges how to tailor supervised-release rules, including internet/device monitoring and how to respond to violations. Takes effect Nov 1, 2025.

Why it matters
  • More consistent rules across courts; still individualized to the person.
  • Clarifies when tech limits and checks are appropriate.
Official & analysis: USSC adopted amendments · Amendments-in-Brief (PDF)
📣 One-minute message (optional)
Send to your federal delegation: Find your U.S. Representative · Contact your U.S. Senators

🏷️ Florida — CS/HB 1351 (Signed; Effective Oct 1, 2025)

In plain terms: Florida passed a broad update to its registration laws. It tweaks definitions and reporting/verification rules starting Oct 1, 2025.

Why it matters
  • Florida’s rules affect many travelers/relocators; changes can trigger reporting surprises.
  • Implementation details will shape day-to-day compliance.
Official & media: Bill page · Governor press (signed)
📣 Prep call to action
Where to send: FDLE Sex Offender Registry (program page) · Find your Florida Senator · Find your Florida Representative

⚖️ Case Watch — Doe v. Lee (6th Cir., Tennessee)

In plain terms: The appeals court said Tennessee courts can’t block the entire registry at once; any injunction must target specific rules shown to be punitive.

Why it matters
  • Relief likely becomes narrower and slower — focused on particular provisions.
  • Document concrete harms tied to specific rules (e.g., housing bans, reporting burdens).
Official & tracker: Opinion (6th Cir.)
📣 Join amicus / story-gathering
Reach your state lawmakers: Find your Tennessee legislators

🗺️ State Highlights (A→W)

Arkansas

  • Act 158 (HB 1437) — Expands “no-go” zones to water parks, swimming areas, and playgrounds in public parks. Act PDF · Bill page
  • Act 972 (SB 490) — Allows courts to waive certain fees when a juvenile is ordered to register. Act PDF

Kansas

HB 2404 — Combined a school-property restriction with a petition-for-relief pathway; did not pass in 2025 (watch for re-intro next session).

Nevada

AB 151 — Proposed Tier II classification for “solicitation of a child for prostitution”; did not advance this session.

NELIS overview · Bill PDF

Pennsylvania

Act 22 of 2025 (from SB 255) — Adds sexual assault by youth-sports officials/volunteers or nonprofit employees to Tier II.

Bill page (Act 22 of 2025)

Washington

SB 5312 — “Net-Nanny” sting cases: proposed 5-year registration (with limited public notice) if no sexual-motivation finding; did not move in 2025.

Senate Bill Report (PDF) · HTML report

West Virginia

HB 3164 — Administrative/fee changes to registry processes.

Enrolled text

No state-level updates posted this week — tap to view list

AL, AK, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NY, OH, OK, OR, PR, RI, SC, SD, TX, VA, VT, WI, WY

⚖️ Court Decisions & Litigation

Oklahoma — Donaldson v. City of El Reno (Okla. Sup. Ct., Feb 4, 2025)

In plain terms: The state high court said the 2,000-ft park rule can apply retroactively because it’s considered non-punitive.

Why it matters
  • Ex-post-facto challenges will likely be decided provision-by-provision (parks vs. schools vs. presence rules).
  • Expect follow-on litigation targeting other specific SORA provisions.

Official & analysis: Opinion (OK Sup. Ct.) · Case tracker summary

Missouri — F.S. v. Missouri Dept. of Corrections (Mo. Sup. Ct., Feb 11, 2025)

In plain terms: The court upheld lifetime GPS monitoring in this case because the person didn’t show enough specific proof that GPS was unconstitutional for them.

Why it matters
  • Future challenges need detailed, person-specific evidence of burden/harm, not only broad arguments.

Official & media: Opinion (PDF) · Justia mirror · Missourinet write-up

10th Circuit — United States v. Kornacki (May 8, 2025)

In plain terms: The appeals court okayed strict internet/device limits (monitoring/approval) for someone on federal supervised release.

Official source: Opinion docket (PDF)

Sixth Circuit — Doe v. Lee (Tennessee, May 12, 2025)

In plain terms: Injunctions must be tailored to specific provisions of the registry shown to be punitive; no blanket “shut the whole thing down” orders.

Official source: Opinion (6th Cir.)

📘 Research & Reports (context)

California CDCR — SOMP 2025 Annual Report

Program outcomes and supervision metrics. (When CDCR posts the public PDF, we can add the direct link.)

📰 Media coverage worth reading

Oklahoma — Donaldson residency retroactivity

Clear explainer on why the court allowed parks restrictions to apply to people with older convictions, and what that could mean for future challenges.

“The decision leaves the door open to challenges against other provisions…”

Read the NonDoc explainer

Missouri — lifetime GPS monitoring case

Quick recap of the Missouri Supreme Court decision upholding lifetime GPS in an as-applied challenge and what evidence future cases might need.

“The court ruled the challenger failed to show GPS monitoring was unconstitutional for him specifically.”

Read the Missourinet recap

📖 Quick Glossary

Residency ban
A rule about where someone may live (for example, near schools or parks).
Retroactive
Applied to someone after their case is over; courts ask if it functions like extra punishment.
Amicus brief
A “friend of the court” filing that offers expertise to help a judge decide a case.
Verification
The required check-in schedule with law enforcement to confirm your information.

👀 Rolling Watchlist

  • Florida — CS/HB 1351: Implementation ahead of Oct 1, 2025. Bill page
  • Michigan — SB 424: Track committee/floor actions. Latest SFA analysis
  • Washington — SB 5312: Potential 2026 re-intro. Bill report
  • Oklahoma — post-Donaldson: Watch new challenges to other SORA provisions.

ℹ️ How we track and vet sources

We link to official documents (court opinions, enrolled acts, agency guidance) and add reputable coverage for context. We also use AI to scan nationwide dockets and calendars so we don’t miss items—but humans review and verify links. See something off? Please let us know and we’ll correct it quickly.