U.S. v. Haslage

Dist. Ct. did not err in dismissing for lack of venue defendant’s indictment charging him with violation of Sex Offender Registration and Notification Act (SORNA), 18 USC section 2250, when he moved from Wisconsin to Washington State without updating his registration. In Nichols, 136 S.Ct. 1113, Supreme Ct. found that sex offender was not required under SORNA to update his registration in state where sex offender had been residing. As such, Wisconsin Dist. Ct. lacked venue to consider instant charge since, although interstate travel is necessary precursor to instant offense, defendant’s act of leaving Wisconsin formed no part of instant offense since mere travel to Washington State did not violate SORNA. Thus, instant SORNA offense could only be prosecuted in Washington State. (Dissent filed.)