507 Mich. 527, 968 N.W.2d 497 (2021)
Michigan’s 2011 registry law is punishment and cannot reach earlier offenses — and courts cannot fix it by reviving an older version.
Good law. Still followed. Later cases may have narrowed it — see Scope. Final word on that state’s own law and constitution — in that state only.
Paul Betts pleaded guilty in 1993, before Michigan had a registry. In 2012 he was charged with failing to report a new address, email address and vehicle within the three days required by the 2011 amendments. He preserved an ex post facto challenge.
The court held that the 2011 SORA is punishment, so applying it to people whose offenses predate the 2011 amendments violates both the U.S. and Michigan ex post facto clauses. It declined to sever the law or revive an earlier version: the 2011 SORA simply cannot be applied to those people. Betts’s conviction was vacated.
Betts brought the Does v. Snyder result into Michigan’s own courts. Its remedy — no fallback to an older law — set up the 2026 ruling in People v. Smith and the mass removals that followed.
It did not decide whether the 2021 rewrite (2020 PA 295) is constitutional, and it did not affect the 2011 law’s application to people whose offenses came later.
Last verified against the sources above on September 30, 2026.
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