United States v. Juvenile Male
131 S. Ct. 2860
| SCOTUS | 2011Background
- Respondent Juvenile Male began sexually abusing a younger boy on the Fort Belknap Reservation; offenses occurred before SORNA but adjudicated in 2005.
- In 2006, Congress enacted SORNA; it requires registration in applicable jurisdictions and applies to some juveniles adjudicated delinquent for serious offenses.
- A prerelease period and juvenile supervision followed respondent’s 2005-2007 sentence; a district court added a special condition requiring SORNA registration.
- Ninth Circuit held that applying SORNA to pre-enactment juvenile delinquents violated Ex Post Facto; the district court’s registration order was vacated.
- Supreme Court granted certiorari and certified a Montana law question about whether respondent’s duty to remain registered depended on the invalidity of the federal conditions.
- Montana Supreme Court answered that Montana’s duty to remain registered is an independent state-law obligation; the initial controversy became moot, and the Ninth Circuit lacked live controversy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the case is moot and can be decided on the merits | Respondent argues mootness exception may apply due to potential collateral consequences. | Government contends no live controversy remains; Montana duty is independent and mootness bars review. | Moot; no actionable controversy remains. |
| Whether Montana’s independent duty to register renders the case capable of repetition yet evading review | Respondent suggests possible repetition of same issues. | Montana duty is independent and respondent will not face the same federal conditions again. | Exception does not apply; mootness governs. |
| Whether the Secretary’s retroactive application of SORNA is reviewable here | Respondent would challenge SORNA as applied to pre-enactment conduct. | Issue focuses on the district court’s conditions, not SORNA’s broader validity. | Not reached; mootness forecloses merits. |
Key Cases Cited
- Arizonans for Official English v. Arizona, 520 U.S. 43 (1997) (case discusses mootness and ongoing injury requirement)
- Spencer v. Kemna, 523 U.S. 1 (1998) (continues the mootness/standing framework for collateral consequences)
- Sibron v. New York, 392 U.S. 40 (1968) (presumption of collateral consequences in criminal convictions)
- DeFunis v. Odegaard, 416 U.S. 312 (1974) (per curiam on mootness and ongoing controversy)
- Weinstein v. Bradford, 423 U.S. 147 (1975) (capable-of-repetition exception to mootness)