Leaving U.S. Still Requires SORNA Registration

U.S. v. Murphy, -- F.3d --, 2011 WL 6739417 (10th Cir. 12/23/11) - Mr. Murphy's SORNA conviction is affirmed. After he was convicted of sex offenses in Utah, Murphy escaped from a SLC halfway house and traveled to Belize without reporting any change. The COA rejects Murphy's argument that because he no longer lived, worked, or studied in the U.S., he was not required to notify Utah of his change of status. A permanent abandonment of an abode constitutes a change of residence that necessitates reporting regardless of whether there has been a formal move to a new place. Mr. Murphy was legally obligated to update his registration in Utah within three days of when he left the halfway house.

Lucero dissents, concluding that a SORNA loophole applies to Murphy. Because Murphy left the state within hours of absconding from the halfway house, there was no point in time while he was in Utah at which he was required to report a change of residence there. And since Belize is not a jurisdiction covered under SORNA, Murphy could not comply with SORNA by reporting his new address to authorities in Belize.