Offender’s Move to Indiana Provides No Relief from Registration Requirement

Earlier this year, I wrote about the most commonly asked question I receive on Indiana’s Sex and Violent Offender Registry: how will moving to Indiana affect my registration requirement? I explained here. Suffice to say, Indiana merely carries over/continues an existing registration requirement across state lines.

Earlier this week, the Court of Appeals of Indiana decided a case reaffirming Indiana’s position in a case with a slightly different set of facts than our prior case law. In Crowley v. State, the petitioner had committed a sex offense in 1988 in Michigan, before either Michigan or Indiana had a registry. Nevertheless, before moving to Indiana in 2004, the petitioner was required to register in Michigan as a result of his conviction. It was not until 2006 that Indiana required residents who were mandated to register in another jurisdiction to register in Indiana. Nevertheless, the Court held the Indiana’s imposition of a duty to register merely maintained the petitioner’s duty from Michigan to register; it did not alter the obligation to result in an added punishment.