US v. Gagnon, 09-1047 - Criminal Law - U.S. First Circuit
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US v. Gagnon, 09-1047

US v. Gagnon, 09-1047, concerned a challenge to a defendant's conviction under the Sex Offender Registration and Notification Act (SORNA).  In affirming the conviction, the court held that US v. DiTomasso is dispositive of the issue of the effective date of SORNA's registration requirements, and the Congress acted within the scope of its authority under the Commerce Clause.  Further, given the unambiguous meaning of section 16913(d), defendant's attempt to invoke the rule of lenity must fail.  Lastly, the court held that the requirements of Due Process Clause are satisfied in this case as notice of a defendant's obligation to register as a sex offender under state law provides him with effective notice of his corresponding obligation to register under SORNA.

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