430 Md. 535, 62 A.3d 123 (2013)
Maryland could not retroactively require registration from someone its law did not cover when he pleaded guilty.
Good law. In 2014 the court added that federal SORNA does not let Maryland require these registrants to register; removal is from the Maryland registry only. Final word on that state’s own law and constitution — in that state only.
A former teacher abused a student in the 1983–84 school year and pleaded guilty in 2006. Maryland’s 1995 registry law did not reach his offense, so a registration order was struck. After his release in 2008, amendments in 2009 and 2010 newly required him to register.
By 6–1, the court held he could not be required to register, but no single rationale won a majority. A three-judge plurality held retroactive registration violated Article 17 of the Maryland Declaration of Rights on a “fair warning” theory. Two judges found the amended law punitive in effect. One relied instead on enforcing the plea agreement.
It added Maryland to the states whose own constitution protects people from retroactive registration, and the 2014 follow-up made clear that the state could not fall back on federal SORNA to keep them registered.
Because the reasoning split three ways, later cases have to work out how far it reaches. Removal from the Maryland registry does not remove a person from federal databases or change any federal SORNA duty.
Last verified against the sources above on September 30, 2026.
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