State high court Overruled

Doe v. Thompson

304 Kan. 291, 373 P.3d 750 (2016)

Kansas’s 2011 registry amendments were held punitive — in a decision overruled the same day it was filed.

Court
Kansas Supreme Court
Decided
April 22, 2016
Reach
None — overruled the day it was decided
Verified
September 30, 2026
Read the opinion All cases

Overruled. Overruled by State v. Petersen-Beard, filed the same day. Final word on that state’s own law and constitution — in that state only.

What happened

A registrant challenged the retroactive application of the 2011 amendments to the Kansas Offender Registration Act under the federal Ex Post Facto Clause. Kansas has no ex post facto clause of its own.

What the court decided

By 4–3, in an opinion by Justice Johnson, the court held the 2011 amendments punitive, so they could not apply retroactively. The majority included a senior judge sitting in a vacant seat.

Why it matters to the Registry

Filed the same day as Petersen-Beard, which overruled it, Thompson shows how much can turn on which judges hear a case: both decisions were 4–3.

What it did not decide

It has no remaining force; Kansas follows Petersen-Beard.

Legal Disclaimer

These are plain-language summaries of court decisions, written for general education. A ruling binds only the courts beneath the court that issued it, later decisions and new laws can change what it means, and how it applies to any one person depends on facts a summary cannot capture. Read the opinion itself, and talk to a lawyer licensed in your state before relying on any case. This page is not legal advice.