U.S. Supreme Court Superseded by statute

Nichols v. United States

578 U.S. 104 (2016)

SORNA, as then written, did not require a registrant to report leaving the country. Congress had already changed that.

Court
U.S. Supreme Court
Decided
April 4, 2016
Reach
Nationwide — but the gap it found has been closed by statute
Verified
September 30, 2026
Read the opinion All cases

Superseded by statute. International Megan’s Law, signed two months before the decision, now requires reporting international travel and makes failing to do so a federal crime. The Court cited it as closing the gap. Binds every court in the country on the federal question it decides.

What happened

Lester Nichols, registered in Kansas, moved to the Philippines without updating his registration. He was brought back and convicted under SORNA for failing to update it.

What the court decided

The Court unanimously reversed. SORNA required updates in a jurisdiction where the person “resides” — present tense. Once Nichols left, Kansas was no longer such a jurisdiction, and the Philippines is not a SORNA jurisdiction, so the law as written did not require him to tell anyone.

Why it matters to the Registry

Nichols is the reason the rules for leaving the country are now explicit. International Megan’s Law (Pub. L. 114-119, Feb. 2016) added intended international travel to the information SORNA requires (34 U.S.C. § 20914(a)(7)) and made knowingly failing to report it a crime (18 U.S.C. § 2250(b)). The 21-day advance notice comes from the Justice Department’s SORNA rule. See our guide to traveling abroad for what applies today.

What it did not decide

The decision reads SORNA’s update duty as it stood before 2016. It does not help anyone traveling today, and the Court noted that Nichols’s conduct also violated Kansas law.

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.