John Doe I v. Robert Williams
2013 ME 24
| Me. | 2013Background
- Multiple John Does challenge Maine’s SORNA of 1999 as amended post-Letalien; trial court granted summary judgment for State officials; some Does petitioned to be removed from the registry and mootness issues arose; remaining Does challenge ex post facto, equal protection, due process, and Maine constitutional claims; amendments in 2009–2010 narrowed burdens but retained reporting; appellate court sustains constitutionality under US and Maine constitutions.
- The retroactive application of SORNA to pre-enactment offenders was central; Letalien held SORNA could punish retroactively for some, prompting legislative amendments clarifying exemptions and reporting changes.
- Letalien’s Mendoza-Martinez framework governs the ex post facto review, focusing on intent and punitive effects; the Court concluded SORNA is civil in intent but subject to seven-factor analysis.
- The Does argued equal protection and due process violations, but the court found no fundamental rights or suspect classifications implicated, applying rational basis review.
- The court also addressed mootness, civil rights claims under MCRA and § 1983, and attorney-fee issues, ultimately affirming dismissal of monetary claims and upholding the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the challenge by Does on mootness viable? | Removed Does retain controversy. | Remedies moot because no relief possible. | Mootness upheld; exceptions not satisfied for removed Does. |
| Does SORNA 1999 as amended violate ex post facto protections? | Ex post facto applies to retroactive punishments. | Civil intent; amendments remedied punitive effects. | SORNA 1999 nonpunitive under Mendoza-Martinez factors; does not violate ex post facto. |
| Does SORNA 1999 violate equal protection? | Ten-year vs lifetime registrants yield unequal treatment. | No fundamental right or suspect class; rational relation to public safety. | Equal protection not violated under rational-basis review. |
| Does SORNA 1999 violate procedural due process? | Stigma-plus concerns and need for hearings. | Registration does not alter liberty; no due process required. | No due process violation; stigma alone insufficient. |
| Does SORNA 1999 violate substantive due process or Maine constitutional rights? | Right to privacy, reputation, and fair treatment infringed. | Statute reasonably related to public safety; no fundamental right. | Substantive due process and Maine constitutional claims fail; no fundamental rights implicated. |
| Are there claims for attorney fees or MCRA remedies? | Prevailing party entitlement or catalyst theory. | No prevailing party status; catalyst theory rejected. | Monetary claims denied; no prevailing party under statute. |
Key Cases Cited
- Letalien, 2009 ME 130 (Me. 2009) (ex post facto review; seven Mendoza-Martinez factors; civil intent vs punitive effects)
- Smith v. Doe, 538 U.S. 84 (U.S. 2003) (intent-effects test; civil vs punitive; ex post facto framework)
- Mendoza-Martinez, 372 U.S. 144 (U.S. 1963) (establishes factors for punitive-exception analysis)
- Doe v. District Attorney, 2007 ME 139 (Me. 2007) (history of Maine sex-offender laws; retroactivity context)
- Haskell, 2001 ME 154 (Me. 2001) (measures addressing registration and punitive considerations)