State v. Pearrow, 248 P.3d 799

Pearrow, previously convicted of a Florida sexual offense, moved to Montana and registered in 2006 under Montana's Sexual Offender Registration Act.
He listed a Belgrade, Montana address and acknowledged duties on the Registration Form, including notice within ten days of a change of address.
Pearrow traveled extensively for work and did not notify law enforcement when traveling or when his residence changed.
Nov 6, 2008, Pearrow vacated the Belgrade address; Nov 17, 2008, began renting RV space in Arizona; Nov 23, 2008, informed Belgrade Police of a change but did not disclose Arizona living.
Belgrade Police ultimately learned Pearrow was living in Arizona; an Information for failing to keep registration current was filed on Dec 24, 2008 under § 46-23-507, MCA.
Pearrow pled nolo contendere to felony failure to register; district court sentenced him with conditions and required continued registration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the registration statutes are unconstitutionally vague as applied.	Pearrow argues vagueness and misapplication by the statute and form.	State contends sufficient notice and compliance under the statute and form.	No; court finds failure to timely update.
Whether the statutes violate Pearrow's substantive due process.	Pearrow asserts due process rights were violated by retroactive changes and notice issues.	State contends ongoing registration obligations are valid and non-arbitrary.	Not reached as dispositive issue resolved otherwise; conviction affirmed on timing.

State v. Samples, 347 P.3d 292 (Mont. 2008) (fair notice required by statute; slight ambiguities do not negate notice)
State v. Leeson, 82 P.3d 16 (Mont. 2003) (statutory interpretation and notice requirements)
State v. G'Stohl, 355 Mont. 43 (Mont. 2010) (presumption of knowledge of Montana law; due process considerations)