United States v. William Bridges
2014 U.S. App. LEXIS 1580
| 4th Cir. | 2014Background
- Bridges was indicted on traveling in interstate commerce and knowingly failing to update his sex offender registration under 18 U.S.C. § 2250.
- He had previously pled nolo contendere to Florida attempted sexual battery with adjudication withheld, and the Florida court imposed probation and required registration as a sex offender.
- The Florida judgment withheld adjudication but imposed penal consequences, including probation and jail credit, triggering Florida registration obligations.
- Bridges moved to dismiss the indictment arguing the Florida plea did not constitute a conviction under SORNA; the district court denied the motion.
- Bridges pled conditional guilty, reserving the right to appeal the district court’s denial of the motion to dismiss.
- The Fourth Circuit held that a nolo contendere plea with adjudication withheld can be a conviction under SORNA because it carries penal consequences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a Florida nolo contendere with adjudication withheld is a SORNA conviction | Bridges contends no conviction under SORNA since adjudication was withheld | United States contends the plea still yields penal consequences making it a conviction | Yes; it constitutes a conviction for SORNA purposes |
| Whether federal law governs the meaning of conviction under SORNA | State-law definitions control whether a conviction exists | Federal law governs the meaning of conviction for SORNA purposes | Federal law governs and supports a federal-interpretation framework |
| Whether the Attorney General guidelines inform the meaning of conviction under SORNA | Guidelines are nonbinding and should not affect the term ‘convicted’ | Guidelines provide the appropriate interpretation of conviction under SORNA | Guidelines inform, and support, the federal meaning of conviction |
| Whether the district court’s denial of the motion to dismiss was correct | The indictment should be dismissed due to lack of a SORNA conviction | The district court properly deemed Bridges convicted under SORNA | Correct; indictment denial affirmed |
Key Cases Cited
- United States v. Maupin, 520 F.3d 1304 (11th Cir. 2008) (nolo contendere with adjudication withheld constitutes a prior conviction for federal offenses)
- United States v. Storer, 413 F.3d 918 (8th Cir. 2005) (nolo contendere with adjudication withheld treated as a conviction)
- United States v. Mejias, 47 F.3d 401 (11th Cir. 1995) (nolo contendere with adjudication withheld constitutes a prior conviction)
- United States v. Willis, 106 F.3d 966 (11th Cir. 1997) (state-law definition of conviction not controlling for federal SORNA purposes)
- Dickerson v. New Banner Inst., Inc., 460 U.S. 103 (1983) (statutory construction and effects of criminal penalties inform conviction concept)
- United States v. Hatcher, 560 F.3d 222 (4th Cir. 2009) (de novo review of legal questions on appeal from denial of indictment motion)
- United States v. Stevenson, 676 F.3d 557 (6th Cir. 2012) (guidelines have force and effect in interpreting SORNA)