Johnson v. Madigan

Dist. Ct. did not err in dismissing for failure to state claim plaintiff’s action alleging that 2011 amendments to Ill. Sex Offender Registration Act (SORA) that labeled him “sexual predator” because of his 1983 rape conviction and because he had committed 2013 felony theft conviction violated ex post facto clause as applied to him, where: (1) his term of required registration for his 1983 rape conviction had expired prior to 2011 amendments; and (2) 2011 amendments would require that he register as sex offender for rest of his life. Pleadings failed to show that amendments to SORA had any retroactive effect, since 2011 amendments stiffened penalty only for plaintiff’s 2013 felony theft conviction, which occurred after 2011 amendments took effect. Ct. rejected plaintiff’s argument that 2011 amendments to SORA were retroactive because they attached new disability to his 1983 rape conviction.