State v. Younger, 2012 Mo. App. LEXIS 1403

Younger was charged with failing to register a change of address under SORA (589.414, 589.425) after allegedly not informing Lafayette County of a new address within three days.
Trial was a bench proceeding; Younger was convicted of a class D felony and sentenced to four years with suspended execution and five years of probation.
Evidence showed Younger had a prior sex-offender conviction (Jackson County, 1994, for sodomy with a minor) and had registered in Lafayette County since 1998 with periodic ninety-day status updates.
On July 14, 2010, Younger reported a new work address in Grant City while listing 200 West 20th Street, Higginsville, as his residence; a certified mail notice was returned undelivered.
Utilities at the Higginsville address were turned off in June 2010 and reconnected in November 2010, with usage suggesting Younger may have been living elsewhere.
A warrant for Younger’s arrest issued September 9, 2010, after Lafayette County authorities investigated the registered address and found no one at the residence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence shows Younger was required to register as a sex offender	Younger	Younger disputed he was obligated to register	Affirmed
Whether evidence shows Younger changed his residence	Younger	Younger argues no change of residence occurred	Affirmed
Whether evidence shows Younger acted knowingly by failing to notify	Younger	Younger argues lack of knowledge	Affirmed

Doe v. Phillips, 194 S.W.3d 833 (Mo. banc 2006) (retrospective application of Megan's Law reregistration)
Doe v. Keathley, 290 S.W.3d 719 (Mo. banc 2009) (lawful extension of SORA registration to those under federal law)
U.S. v. Van Buren, 599 F.3d 170 (2d Cir. 2010) (change of residence includes leaving a registered residence with no intention to return)
State v. Kelly, 367 S.W.3d 629 (Mo. App. E.D. 2012) (left residence with no intent to return can trigger reporting duty)