Reynaldo Parado Rodriguez v. State, 108 A.3d 438

In 1996 Reynaldo Parado Rodriguez (then 26) had sexual intercourse with a 15‑year‑old and pled guilty in 1998 to third‑degree sexual offense; sentenced in 1999 to probation and short jail exposure.
MSORA initially did not require him to register; successive legislative amendments (1999, 2001, 2010) altered registration obligations and retroactivity rules.
A 2001 retroactivity provision brought Rodriguez onto the registry for life; he was notified in 2007. The 2010 reform reclassified tiers and reduced his registration term to 25 years but added new duties for homeless registrants, including weekly in‑person reporting.
Rodriguez became homeless in August 2011, failed to comply with the 2010 homeless‑registrant weekly in‑person reporting requirement, and was indicted for failing to register.
At a bench hearing Rodriguez admitted the failure to register but argued MSORA’s retroactive application (per Doe litigation) and the plea agreement precluded enforcement; trial court convicted and sentenced him.
On appeal Rodriguez raised (1) insufficiency/ex post facto challenge to the retroactive homeless‑registration duty and (2) that his predicate plea agreement barred the registration requirement. The Court of Special Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient because MSORA’s retroactive application violated Maryland’s ex post facto prohibition so Rodriguez had no duty to register	Rodriguez: Doe I shows retroactive application of later MSORA amendments is unconstitutional; thus he lacked legal duty and evidence is insufficient	State: Rodriguez was placed on registry by 2001 retroactivity (not the 2009 provision at issue in Doe I); only the 2010 homeless weekly reporting requirement was newly applied and it does not add punishment	Court: Affirmed — Doe I inapposite; 2001 placement valid; weekly in‑person homeless reporting is a regulatory (not punitive) requirement and its retroactive application does not violate Article 17, so conviction stands
Whether the predicate plea agreement (which did not contemplate registration) precludes enforcement of registration and requires vacatur	Rodriguez: Plea did not include registration, so he never had duty to register; plea should be enforced	State: Issue was not raised below and is not preserved for appeal; Court need not reach the merits	Court: Declined to decide on the merits due to preservation rule and affirmed conviction

Dep’t of Pub. Safety & Corr. Servs. v. Doe, 430 Md. 535 (2013) (Court of Appeals plurality holding certain retroactive MSORA amendments violated Article 17 ex post facto prohibition)
Dep’t of Pub. Safety & Corr. Servs. v. Doe, 439 Md. 201 (2014) (subsequent related proceedings addressing registration ordering and procedural posture)
Twine v. State, 395 Md. 539 (2006) (homeless registrant not covered by earlier statute version’s change‑of‑address rule)
Sinclair v. State, 199 Md. App. 130 (2011) (registration challenges are civil/collateral and generally require a separate declaratory action, not relief in the criminal cause)
Young v. State, 370 Md. 686 (2002) (pre‑2001 MSORA analyzed under due process; Court’s holding not a review of 2001 amendments under Article 17)
United States v. Gould, 568 F.3d 459 (4th Cir. 2009) (interpreting federal SORNA failure‑to‑register elements to include that defendant was required to register)