In Re Von, 146 Ohio St. 3d 448

Aaron K. Von, convicted in Colorado in 1997 of sexual-assault offenses, moved (in Ohio) to terminate his duty to register as a sex offender under R.C. 2950.15 (enacted as part of the Adam Walsh Act, effective Jan. 1, 2008).
The State opposed, arguing R.C. 2950.15 applies only to offenders convicted for offenses committed on or after Jan. 1, 2008 and citing State v. Williams (holding Adam Walsh Act cannot be retroactively applied).
The trial court denied Von’s termination motion, concluding Megan’s Law (the pre-2008 regime) contained no termination procedure and later amendments were not retroactive.
The appellate court reversed, holding R.C. 2950.15’s language (“regardless of when the offense was committed”) permits retroactive relief for eligible (Tier I) offenders and remanded to determine Von’s tier/classification.
This Court accepted the State’s appeal to decide whether R.C. 2950.15’s termination procedure may be applied to offenders whose offenses occurred before Jan. 1, 2008.
The Supreme Court held R.C. 2950.15 does not apply to pre-2008 offenders because they cannot constitutionally be classified under the Adam Walsh Act tiers; remanded for the trial court to determine Von’s classification under Megan’s Law.

Issue	Plaintiff's Argument (Von)	Defendant's Argument (State)	Held
Whether R.C. 2950.15’s termination procedure (Adam Walsh Act) applies to offenders who committed offenses before Jan. 1, 2008.	R.C. 2950.15 applies “regardless of when the offense was committed,” so Von is eligible to move to terminate registration if he is (or can be) treated as a Tier I offender.	Only Tier I offenders are eligible; under Williams the Adam Walsh Act tiers cannot be constitutionally applied retroactively to pre-2008 offenders, so pre-2008 offenders cannot be reclassified as Tier I and cannot use R.C. 2950.15.	R.C. 2950.15 does not apply to offenders who committed offenses before Jan. 1, 2008; such offenders cannot constitutionally be classified under the Adam Walsh tiers and thus are not "eligible offenders" under R.C. 2950.15. The case is remanded to determine Von’s Megan’s Law classification.

State v. Williams, 129 Ohio St.3d 344 (2011) (Adam Walsh Act punitive as applied retroactively; violates Ohio constitutional ban on retroactive laws)
In re Bruce S., 134 Ohio St.3d 477 (2012) (only offenses committed on or after Adam Walsh Act effective date may be subjected to its classification scheme)
Bundy v. State, 143 Ohio St.3d 237 (2015) (describes repeal of Megan’s Law and replacement by Adam Walsh Act classification scheme)