What happened
Eddie Lee Smith’s offenses were in 1995 and 2010, but he was required to register under the 2021 SORA (2020 PA 295, effective March 24, 2021). The Court of Appeals upheld that requirement.
State high court Good law
People v. Smith
No. 168200 (Mich. Sept. 9, 2026) (order)
Michigan’s 2021 registry law cannot reach pre-2011 offenses. More than 20,000 people came off the registry within days.
- Court
- Michigan Supreme Court
- Decided
- September 9, 2026
- Reach
- Michigan — everyone whose offense predates the 2011 amendments
- Verified
- September 30, 2026
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.
What the court decided
In a unanimous order entered in lieu of granting leave to appeal, the court reversed. Relying on Kardasz, it held that the requirements enacted after his crimes amount to punishment, so applying the 2021 SORA to him is ex post facto. Following Betts, it held that severing the statute or reviving an earlier version is not an available fix. The case was remanded to the Kent Circuit Court.
Why it matters to the Registry
It is the largest single change to a state registry in this library. The Michigan State Police reported on September 11, 2026 that more than 20,000 of roughly 43,000 registrants had been removed, with review continuing.
What it did not decide
It applies only to people whose registerable conduct predates the 2011 amendments. It does not affect later offenses, federal SORNA duties, or registration requirements in other states for people who move.
Related
Related cases
- People v. KardaszState high court · 2025
- People v. BettsState high court · 2021
- Does #1–5 v. SnyderFederal appeals court · 2016
The statute in LawLookup
Registry Wire coverage
Sources
- Order — Michigan Supreme Court (No. 168200) (primary)
- Michigan State Police — SOR compliance statement (Sept. 11, 2026)
Last verified against the sources above on September 30, 2026.
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.