State v. Larson, 2014 Ohio 4685

Larson was convicted in 1991 of gross sexual imposition, kidnapping, and four counts of rape, receiving multiple long prison terms.
Megan’s Law (HB 180) and SB 10 led to retroactive sex-offender classifications and later the Adam Walsh Act framework.
Bodyke (2010) held retroactive AWA/sb10 registration violated separation of powers, affecting classification status.
ODRC proposed sex-predator hearings for inmates in 2012, leading Larson to file a motion to dismiss in 2013.
Lorain County C.P. granted Part/Denied Part of Larson’s petition in 2010, reinstating prior sex-offender classification; district later conducted new hearings.
Trial court conducted a 2014 sexual predator hearing and classified Larson as a sexual predator despite prior classifications.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred denying the motion to dismiss	Larson argues reinstated prior classification bars reclassification	Court may conduct SB 10/AWA hearing before release	No error; hearing valid and classification supported by evidence

State v. Bodyke, 126 Ohio St.3d 266 (2010) (retroactive AWA/SB10 unconstitutional as applied to pre-enactment offenders)
State v. Williams, 2011-Ohio-3374 (Ohio) (constitutional concerns with retroactive sex-offender laws)
State v. Bonneau, 2013-Ohio-5021 (Ohio) (Megan’s Law retroactivity does not violate Ohio Constitution)
State v. Caraballo, 8th Dist. Cuyahoga No. 89757, 2008-Ohio-2046 (Ohio) (trial court need not assess every factor; supported by clear and convincing evidence)
State v. Ferguson, 8th Dist. Cuyahoga No. 88450, 2007-Ohio-2777 (Ohio) (court’s weight given to factors consistent with statute)