Lyttle v. State, 191 Ohio App. 3d 487

Lyttle pled guilty in 1991 to four counts of gross sexual imposition and was sentenced in 1992 to four consecutive two-year terms.
Before release, on March 14, 1997, the trial court adjudicated him a sexual predator under Megan’s Law, effective January 1, 1997; he was released March 18, 1997.
Lyttle I (1997) affirmed the sexual-predator classification, with Megan’s Law address-registration requirements taking effect July 1, 1997.
In November 2007, Lyttle received a letter informing him of reclassification as a tier III offender under the Adam Walsh Act; he filed a petition in February 2008 challenging the reclassification.
At a January 2010 hearing, Lyttle argued he was exempt from Megan’s Law registration because he completed his sentence before July 1, 1997, and thus was not subject to the new duties.
After Bodyke (2010) severed the Adam Walsh Act provisions, the court held it had no petition process or jurisdiction to rule, so the petition was moot and the appeal was dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the trial court’s registration obligation reviewable?	Lyttle (plaintiff) argues Megan’s Law duties applied.	Lyttle’s reclassification and registration duties are governed by the Adam Walsh Act.	Assignment dismissed; moot due to severance and lack of jurisdiction.
Does law-of-the-case prevent review of registration obligations?	Lyttle contends Lyttle I controls and bars challenge.	State argues law-of-the-case bars re-litigation of registration issues.	Assignment dismissed; moot for lack of jurisdiction.

State v. Bodyke, 126 Ohio St.3d 266 (2010) (severance of Adam Walsh Act provisions; reinstatement of prior Megan’s Law classifications)
Chojnacki v. Cordray, 126 Ohio St.3d 321 (2010) (mootness after severance; no justiciable controversy for petition-based challenges)
State v. Bellman, 86 Ohio St.3d 208 (1999) (pre-July 1, 1997 release means no registration under 2950.04(A)(1))