State v. Edwards, 148 Conn. App. 760

Edwards, a life-long sex offender, was on probation for a 1999 robbery conviction beginning December 17, 2008, through December 17, 2013.
As a standard probation condition, he agreed not to violate any criminal laws.
On August 13, 2010, Edwards was arrested for failing to notify the registry of an address change under § 54-251 (a) and (e).
At a 2011 probation-violation hearing, officer Reilly testified Edwards’ registry address was 73 Fresh Meadow Road but he found no evidence Edwards lived there.
Edwards testified he had been evicted in mid-2010 and then lived in a box truck on the property or, alternatively, inside the home on the second floor, with some bills in his name through September 2010.
The trial court concluded Edwards violated § 54-251 by becoming homeless and failing to inform the Commissioner, and it revoked probation; the appellate court reversed, holding homelessness does not automatically equal a change of address and remanded for entry of judgment in Edwards’ favor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What constitutes a residence address under §54-251?	State contends residence address changes require reporting a new location.	Edwards argues homelessness does not necessarily constitute a change of address.	Statutory change of address requires a new residence location; homelessness alone is not necessarily a change.
Did the trial court misinterpret homelessness as a change of address for probation violation?	State asserts homelessness triggers reporting changes.	Edwards asserts the law requires an identifiable new residence, not mere homelessness.	Court erred by equating homelessness with a change of address; reversal warranted.
Was there sufficient evidence to prove a change of residence under §54-251?	State argued that eviction and homelessness necessitated address reporting.	Edwards contends no proof of a new residence location other than the prior address.	Evidence did not prove Edwards acquired a new residence; violation not established.
Should the court rely on Drupals' residence-address standard to interpret §54-251?	State relies on broader readings of homelessness as a change of address.	Edwards relies on Drupals’ definition that residence is where one lives for some time.	Court should apply Drupals’ definition; homelessness does not automatically equate to a new residence.

State v. Drupals, 306 Conn. 149 (2012) (defines residence address as the act of living in a given place)
State v. Welch, 40 Conn. App. 395 (1996) (standard for reviewing probation-violation factual findings)
State v. Hooks, 80 Conn. App. 75 (2003) (standard for reviewing sufficiency of evidence in probation cases)
State v. Winer, 112 Conn. App. 458 (2009) (discusses homeless registrants and residence requirements under § 54-251)
State v. Stratton, 130 Wn. App. 760 (2005) (transient offender living in car; discussion of residence vs. address)
Robinson v. State, 6 So. 3d 677 (Fla. App. 2009) (addressing homelessness and registration implications)