State v. Alexander, 2011 Ohio 4015

Appellant Lance Alexander was convicted of failure to notify after being reclassified from Megan's Law to the Adam Walsh Act (AWA) Tier III offender.
The AWA replaced Megan's Law in 2008, changing notification rules to every 90 days for life, with change-of-address notices required prior to moving.
Bodyke (June 2010) held AWA reclassification provisions unconstitutional and reinstated original Megan's Law classifications and obligations for those previously adjudicated under Megan's Law.
Gingell (2011) clarified consequences of retroactive application of AWA and reinstatement of Megan's Law obligations for defendants reinstate under Bodyke.
During trial, after Bodyke was issued, the court and parties discussed applicability; the record indicates a potential change in law affecting the case.
The trial evidence showed appellant lived at Spanish Villa address and failed to notify the sheriff prior to moving, despite initial registration at Chandler Drive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction is valid given unconstitutional reclassification under Bodyke.	State argues Bodyke issues do not negate liability under the current statute.	Alexander argues AWA reclassification was unconstitutional and cannot support conviction.	Merits: reclassification unconstitutional; conviction should be third-degree.
Whether the evidence supports conviction under the prior and current notification requirements.	State contends evidence shows failure to notify under applicable statute.	Alexander contends the reinstated Megan's Law framework could negate guilt or alter degree.	Merits: evidence supports guilt, but degree should be third-degree; weight/sufficiency not independently dispositive.
Whether the conviction is against the manifest weight of the evidence.	State asserts the jury could reasonably find guilt beyond a reasonable doubt.	Alexander argues the record does not clearly support the finding given conflicting address evidence.	Merits: conviction not against the manifest weight; evidence sufficient to sustain.

State v. Bodyke, 126 Ohio St.3d 266 (2010-Ohio-2424) (AWA reclassification unconstitutional; reinstates Megan's Law obligations)
State v. Gingell, 128 Ohio St.3d 444 (2011-Ohio-1481) (clarifies effects of Bodyke on AWA reclassifications)
State v. Johnson, Montgomery App. No. 24029, 2011-Ohio-2069 (2011-Ohio-2069) (reclassification issues; compatibility with notification statute)
State v. Milby, Montgomery App. No. 23798, 2010-Ohio-6344 (2010-Ohio-6344) (continued liability for prior notification; adjust degree after Bodyke)