Alex Jordan Vaughn v. State
2017 WY 29
Wyo.2017Background
- In May 2011 a 17‑year‑old Alex J. Vaughn was adjudicated a delinquent for a serious sexual offense under Wyoming’s Juvenile Justice Act (WJJA); his juvenile file was later closed and sealed.
- In July 2011 the Wyoming Sexual Offender Registration Act (WSORA) was amended to define “convicted” to include certain juvenile adjudications, and that amendment applied retroactively.
- Vaughn was required to register under WSORA; in 2014 he failed to update his address and was charged with two felonies for failing to keep his registration current.
- Vaughn pleaded guilty conditionally, preserving constitutional challenges to WSORA, and appealed after the district court denied his motion to dismiss.
- He raised four constitutional claims: conflict with WJJA (rule of lenity), state equal protection, due process (reputation/confidentiality and irrebuttable presumption), and federal ex post facto prohibition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WSORA §7‑19‑301(a)(iii) conflicts irreconcilably with WJJA confidentiality | Vaughn: WSORA’s registration/notification conflicts with WJJA’s confidential, rehabilitative scheme; ambiguity favors defendant (lenity) | State: WJJA’s purpose includes public protection and can be read harmoniously with WSORA’s limited notification | Court: No conflict; statutes are reconcilable and WSORA’s limited disclosure furthers public safety; lenity not triggered |
| Equal protection under Wyoming Constitution | Vaughn: Adults receiving 7‑13‑301 deferrals avoid conviction/registration but juveniles cannot, creating unequal treatment | State: Juveniles have analogous consent‑decree deferral (WJJA §14‑6‑228); no meaningful classification difference | Court: No equal protection violation—juveniles have similar deferral mechanism; distinction is permissible |
| Due process: lifetime registration violates reputation/confidentiality and creates irrebuttable presumption of dangerousness | Vaughn: Registration publicly stigmatizes and forecloses challenge to continuing dangerousness (substantive/procedural due process) | State: No fundamental right to reputation/confidentiality; WSORA is rationally related to public safety; registration is regulatory, not punitive; no entitlement to a second hearing on dangerousness | Court: No due process violation—no fundamental right implicated; rational basis applies; registration is regulatory and not an irrebuttable presumption requiring another hearing |
| Ex post facto (U.S. Const., Art. I, §10) | Vaughn: Retroactive imposition of WSORA registration on pre‑amendment juvenile adjudications is punitive and thus violates ex post facto | State: WSORA is civil/regulatory in intent and effect (per prior precedent) | Court: WSORA is nonpunitive as applied to juvenile adjudications under Smith/Smith‑framework; does not violate ex post facto clause |
Key Cases Cited
- Kammerer v. State, 322 P.3d 827 (Wyo. 2014) (analyzing WSORA under Smith framework and holding registration scheme regulatory not punitive)
- Snyder v. State, 912 P.2d 1127 (Wyo. 1996) (earlier Wyoming treatment of sex‑offender registration and public safety rationale)
- Smith v. Doe, 538 U.S. 84 (U.S. 2003) (two‑step test to determine whether a sex‑offender law is punitive for ex post facto purposes)
- Paul v. Davis, 424 U.S. 693 (U.S. 1976) (reputation alone does not implicate a liberty interest sufficient for due process protection)
- In re J.W., 787 N.E.2d 747 (Ill. 2003) (juvenile registration does not inherently conflict with juvenile justice goals; registration constitutionally permissible as applied to juveniles)