United States v. Coleman, 2012 U.S. App. LEXIS 6341

Coleman was convicted of sexual battery in Ohio in 2002, triggering a duty to register as a sex offender under Ohio law.
Three days before release, Coleman signed a notice in July 2005 to register in Ohio or any state he resided in within five days of arriving; he did not register.
Coleman later moved permanently to Kentucky and again failed to register.
Between May 2008 and mid-February 2009, Coleman made sporadic trips from Kentucky to West Virginia, including after SORNA took effect on August 1, 2008.
On August 6, 2009, Coleman was indicted for violating 18 U.S.C. § 2250(a) for failure to register; he moved to dismiss the indictment as unconstitutional, the district court denied, and he pled guilty reserving the right to appeal the denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ex Post Facto challenge to SORNA	Coleman argues SORNA imposes punishment for pre-enactment conduct.	Coleman contends SORNA retroactively increases punishment or removes a defense.	No Ex Post Facto violation; statute valid as applied.
Commerce Clause challenge to SORNA	SORNA exceeds Congress's power under the Commerce Clause.	SORNA properly regulates interstate channels or instrumentalities related to travel.	SORNA valid under Lopez prongs 1 and 2; district court did not err in denying dismissal.

Carr v. United States, 130 S. Ct. 2229 (2010) (SORNA enacted under AWCPA; liability requires post-enactment travel and registration)
United States v. Lopez, 514 F.3d 549 (1995) (three Lopez categories for Congress's commerce power)
United States v. Morrison, 529 U.S. 598 (2000) (explanation relevant to VAWA provisions and commerce power limits)
United States v. Page, 167 F.3d 325 (1999) (interstate travel as a jurisdictional element supporting commerce power)
United States v. Al-Zubaidy, 283 F.3d 804 (2002) (jurisdictional element anchoring federal regulation of non-economic activity)