Commonwealth v. Woodruff
135 A.3d 1045
| Pa. Super. Ct. | 2016Background
- Appellant Matthew Woodruff was convicted in 2002 of indecent assault of a minor under 13.
- Under Megan’s Law II, he had a ten-year registration period and annual reporting to PSP.
- SORNA was enacted in 2011 and became effective in 2012, classifying his 2002 conviction as Tier III with lifetime registration and quarterly in-person reporting if applicable.
- Woodruff filed a petition in 2014 seeking reassessment of his registration period and arguing ex post facto and improper punitive effect.
- The trial court denied the petition in 2015; Woodruff appealed the ex post facto ruling to the Superior Court.
- The court applied the Smith v. Doe framework and Mendoza–Martinez factors to determine whether SORNA’s effects are punitive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SORNA’s retroactive lifetime registration and quarterly reporting are punitive ex post facto. | Woodruff contends SORNA is punitive in effect and violates ex post facto. | Commonwealth argues SORNA is civil/regulatory, with non-punitive legislative intent. | Not punitive; overall balance weighs against ex post facto violation. |
| Whether the Mendoza–Martinez factors support finding SORNA punitive as applied to Woodruff. | Woodruff asserts first and second factors weigh punitive; seeks punitive label under others. | Commonwealth argues most factors do not show punitive effect; Perez guidance applied. | First and second factors weigh punitive, but the remaining factors and overall balance do not, so no punitive finding. |
| Whether the court should adopt Perez/Williams II reasoning to evaluate SORNA’s punitive effects and the sufficiency of the first prong. | Woodruff urges Perez-based reasoning for in-person, semi-annual reporting as punitive. | Commonwealth relies on Smith, Perez, and Williams II to frame non-punitive purposes. | Court accorded Perez reasoning with respect to first factor but ultimately balanced all factors against punitive characterization. |
Key Cases Cited
- Smith v. Doe, 538 U.S. 84 (U.S. 2003) (framework for determining whether a statute is civil or punitive under Mendoza–Martinez)
- Commonwealth v. Williams, 832 A.2d 962 (Pa. 2003) (Megan’s Law II punitive analysis under Mendoza–Martinez factors; discusses counseling and registration)
- Commonwealth v. Perez, 97 A.3d 747 (Pa. Super. 2014) (analyzed SORNA’s 25-year registration as punitive vs. non-punitive purposes; applied Mendoza–Martinez)
- Commonwealth v. Gaffney, 733 A.2d 616 (Pa. 1999) (Megan’s Law I non-punitive aspects; early ex post facto analysis under different precedent)
- Commonwealth v. Lehman, 839 A.2d 265 (Pa. 2003) (set forth Mendoza–Martinez factors as guiding framework)
- Coppolino v. Noonan, 102 A.3d 1254 (Pa. Cmwlth. 2014) (in-person quarterly verification weighed punitive under Mendoza–Martinez)