State v. David Leroy Lee, 286 P.3d 537

Lee moved from his Boise address after 2001 and cut off his ankle bracelet; no change of address was filed with the Sheriff or Registry; Registry sent notices to last known address which were returned; Lee was arrested in Belize and extradited to Idaho; charged with failure to register under I.C. § 18-8309; district court denied motion for acquittal and jury convicted; Court of Appeals affirmed; Idaho Supreme Court granted review to determine sufficiency and related arguments.
Lee contends I.C. § 18-8309 does not apply to moves to another country, that the State failed to prove a new Idaho address, and that the statute is vague or violates due process.
The State argues § 18-8309 covers changes of address even when leaving the country and that the State need only prove Lee moved from his last address without notice; the district court rejected these arguments and Lee was convicted.
The Supreme Court vacates the district court’s judgment and enters judgment of acquittal based on the statute not applying to moves to another country and lack of proof of a new Idaho address.
Parole conditions (ankle monitor) and annual/biannual registration obligations preceding 2001 are noted, but no further discussion of parole or updated registration is addressed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §18-8309 applies to moves to another country	Lee: statute does not cover country moves	State: statute applies to changes of address, including international moves	Statute does not apply to country moves
Whether State proved a new Idaho address	Lee did not establish a new Idaho address after leaving Boise	State relied on post office evidence and presumed knowledge	Insufficient evidence of a new Idaho address beyond reasonable doubt
Whether constitutional challenges were properly before the court	Lee's vagueness/due process claims should be addressed	Court should avoid constitutional issues if other grounds decide the case	Declines to address constitutional issues; decides on statutory interpretation and evidence
Standard of review on sufficiency of evidence	Guilt not proven beyond reasonable doubt	Evidence supports conviction under §18-8309	Evidence insufficient to sustain conviction; acquittal warranted

State v. Corbus, 150 Idaho 599, 249 P.3d 398 (2011) (independent review of trial court denial of judgment of acquittal)
State v. Mercer, 143 Idaho 108, 138 P.3d 308 (2006) (defining standard for reviewing acquittals)
State v. Grube, 126 Idaho 377, 883 P.2d 1069 (1994) (guilt beyond reasonable doubt standard)
Henderson v. Smith, 128 Idaho 444, 915 P.2d 6 (1996) (statutory interpretation and retroactivity considerations)
Twin Falls Cnty. v. Hulbert, 66 Idaho 128, 156 P.2d 319 (1945) (use of 'state' in statutes implying domestic territorial scope)