People v. Pearse, 2017 IL 121072

Brian Pearse, a registered sex offender, was admitted to a Forest Park hospital in January 2012; a Forest Park officer completed a registration form listing the hospital as the "resident address" and Pearse's Belvidere home as a "secondary address."
Belvidere police later located Pearse at his Belvidere apartment after he left the hospital and arrested him for failing to register his address within three days under section 3 of the Sex Offender Registration Act (730 ILCS 150/3 (West 2012)).
The indictment charged Pearse under section 3 for failing to "register a change of address," but at trial the parties and the court disputed whether the offense charged was a failure to "establish" (or re-establish) a residence under §3(b) or a failure to notify under §6.
The trial court instructed the jury that Pearse committed the offense if he "established a fixed residence or temporary domicile different from his last place of registration" and failed to report the change within three days; the jury convicted Pearse.
The appellate court affirmed, reading §3(b) to require "reregistration" upon return to a previously registered address; this Court reversed, holding the State failed to prove a §3 violation and that the statutory scheme requires notice to the law-enforcement agency of the jurisdiction being left rather than re-registration at the prior address.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Pearse was required to "reregister" his previously registered Belvidere address after a short hospital stay (i.e., whether §3(b) requires reestablishing registration upon return)	§3(b) ("regardless of any initial, prior, or other registration") requires registration within 3 days of "establishing" (or reestablishing) a residence, so Pearse had to register with Belvidere when he returned	Pearse had already registered both locations on Jan. 5 (hospital + Belvidere); §3 means add new residences, not cancel or re-register prior addresses; no statutory duty to reregister on return	Reversed: No statutory basis to require re-registration of a previously registered address; the scheme requires notification to the agency of the jurisdiction being left (per §3(a) referencing §6), not re-registration at the prior address
Whether instructional error required reversal (jury was instructed Pearse "established" a different fixed residence)	Instructions correctly stated elements under the State's reading of §3	Instructions misstated law because conviction rested on a construction of §3(b) that the Court rejected	Court did not reach full instructional analysis because State failed to prove a §3 violation; conviction reversed

People v. Malchow, 193 Ill. 2d 413 (Ill. 2000) (Registration Act purpose: assist law enforcement and protect the public)
People v. Cornelius, 213 Ill. 2d 178 (Ill. 2004) (same: Registration Act facilitates law enforcement access to offender information)
People v. Molnar, 222 Ill. 2d 495 (Ill. 2006) (criminal statutes must give fair notice and definite standards)
People v. Johnson, 225 Ill. 2d 573 (Ill. 2007) (statutory-construction principles and legislative intent take precedence)