2009 ME 130, 985 A.2d 4
Maine could not retroactively turn a registration term that was part of a 1996 sentence into lifetime registration with no way out.
Good law. It applies only to people sentenced between mid-1992 and late 1999, when registration was part of the sentence. Final word on that state’s own law and constitution — in that state only.
Letalien pleaded guilty to gross sexual assault and was sentenced in August 1996, when Maine’s law made registration part of the sentence: fifteen years, with a waiver possible after five. A 2001 amendment made the state’s 1999 registration act retroactive, which moved him to lifetime registration with no waiver and in-person verification every 90 days.
Treating the federal and Maine ex post facto clauses (Me. Const. art. I, § 11) as the same, the court held that for people sentenced between June 30, 1992 and September 17, 1999 — whose registration was part of the sentence — retroactive lifetime registration with no chance of relief is an unconstitutional ex post facto law. It stayed its mandate so the Legislature could respond.
Letalien ties the punitive finding to the fact that registration had been part of the sentence itself — so increasing it later looked like increasing the sentence.
It covers only that sentencing window. It did not decide due process claims or the earlier 1988–1992 group, and it does not reach people registered under the post-1999 law.
Last verified against the sources above on September 30, 2026.
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