129 Ohio St.3d 344, 2011-Ohio-3374
Ohio’s Adam Walsh Act tiers are punitive and cannot apply to anyone whose offense came before the law took effect.
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.
Williams committed his offense before Ohio’s S.B. 10 — its version of the federal Adam Walsh Act — took effect on January 1, 2008. He was then classified under S.B. 10 as a Tier II offender: 25 years of registration with in-person verification every 180 days.
By 5–2, in an opinion by Justice Pfeifer, the court held that S.B. 10 is punitive, and applying it to anyone who committed an offense before its enactment violates the Retroactivity Clause of the Ohio Constitution (art. II, § 28). He was to be sentenced under the law in effect when he committed the offense.
It returned people with pre-2008 offenses to Ohio’s earlier system, so Ohio now runs two registration schemes depending on the date of the offense.
The court expressly declined to reach the federal Ex Post Facto Clause. It does not affect offenses committed after S.B. 10 took effect.
Last verified against the sources above on September 30, 2026.
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