565 U.S. 432 (2012)
SORNA did not reach people convicted before 2006 until the Attorney General validly said it did.
Good law. Still followed. Later cases may have narrowed it — see Scope. Binds every court in the country on the federal question it decides.
Billy Joe Reynolds was convicted before SORNA and registered in Missouri in 2005. In 2007 he moved to Pennsylvania without registering. He argued that the Attorney General’s February 2007 interim rule, which applied SORNA to pre-Act offenders, was invalid. The Third Circuit held that SORNA applied to him regardless of the rule.
By 7–2, the Court reversed. SORNA’s registration requirements do not apply to pre-Act offenders until the Attorney General validly specifies that they do. Whether the interim rule was valid therefore matters.
Reynolds sent courts back to examine the Justice Department’s rules for older convictions and led directly to the delegation challenge in Gundy.
It did not decide whether the interim rule was valid under either the nondelegation doctrine or the Administrative Procedure Act.
Last verified against the sources above on September 30, 2026.
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