T.L. Jackson v. Com. of PA, 143 A.3d 468

In 1991 Tommy Lee Jackson pleaded guilty in Texas to Indecency with a Child by Contact; he completed probation/prison and was discharged from supervision in 2003.
Jackson registered as a sex offender in Texas (1997–2002) and Delaware (2002) before moving to Pennsylvania in June 2004, having registered about six years out-of-state prior to relocating.
When Jackson moved to Pennsylvania, Megan’s Law II required ten years of registration for the Pennsylvania-equivalent offense; PSP treated his registration period as running from June 25, 2004 to June 25, 2014.
SORNA (Megan’s Law IV) took effect December 20, 2012 and reclassified Jackson as a Tier III offender requiring lifetime registration; PSP did not credit his prior out-of-state registration time.
Jackson petitioned for relief asking PSP to remove him from SORNA registration — arguing (a) his registration period expired before SORNA or (b) SORNA’s application violates Equal Protection by failing to credit out-of-state registration.
The court granted Jackson summary relief on Equal Protection grounds, ordered PSP to remove him from SORNA registration, and denied PSP’s cross-motion.

Issue	Jackson's Argument	PSP's Argument	Held
Whether Jackson completed his registration period pre-SORNA and thus is not subject to SORNA	He should receive credit for ~6 years of out-of-state registration so his 10-year period expired before SORNA	Under Megan’s Law II and SORNA, out-of-state registration does not get credit; his Pennsylvania registration began in 2004	Court found PSP erred in not crediting him; concluded he had completed his registration period prior to SORNA and thus was not subject to it (decision reached on Equal Protection grounds)
Whether applying SORNA without crediting out-of-state registration violates Equal Protection	Treating out-of-state offenders worse (lifetime under SORNA) than similarly situated in-state offenders (who completed 10 years pre-SORNA) is arbitrary and not reasonably related to public safety	Classification is rationally related to valid state interests (public safety, preventing avoidance of registration) and treats similarly situated Megan’s Law II offenders the same	Court held PSP’s refusal to credit out-of-state registration was arbitrary, not reasonably related to the statute’s objective, and violated the Equal Protection Clause; ordered removal from SORNA

Commonwealth v. Neiman, 84 A.3d 603 (Pa. 2013) (Megan’s Law III struck down under Pennsylvania single‑subject rule)
Doe v. Miller, 886 A.2d 310 (Pa. Cmwlth. 2005) (rational‑basis review framework for classifications in sex‑offender statutes)
Commonwealth v. Gaffney, 733 A.2d 616 (Pa. 1999) (Megan’s Law purpose is public safety, not punitive)
Commonwealth v. Gomer Williams, 832 A.2d 962 (Pa. 2003) (analysis of Megan’s Law’s purpose and classifications)
Taylor v. Pennsylvania State Police, 132 A.3d 590 (Pa. Cmwlth. 2016) (context on SORNA enactment and relation to prior Megan’s Law iterations)