United States v. Juvenile Male

Background

A teenage boy was adjudicated delinquent for sexual abuse while he was 13–15 years old and was sentenced to juvenile detention followed by supervision until his 21st birthday. The District Court added a special condition requiring him to register as a sex offender. Congress later enacted SORNA, which requires certain offenders to register and includes rules treating some earlier convictions as covered. The juvenile appealed the registration condition to the Ninth Circuit while still under supervision.

Reasoning

Before the Ninth Circuit decided, the juvenile turned 21 and his federal juvenile supervision expired, so he was no longer subject to the registration condition. The Supreme Court focused on whether there remained a live controversy that a court could fix. The Court explained that overturning the federal supervision condition would not remove the juvenile’s obligation to remain on Montana’s sex-offender registry, because Montana law makes that duty independent of the federal order. The Court therefore found no ongoing injury traceable to the expired supervision and concluded the appeals court lacked authority to decide the merits.

Real world impact

The Supreme Court vacated the Ninth Circuit’s decision and remanded with instructions to dismiss the appeal. That action leaves the state registration requirement in place and means this opinion does not resolve, on the merits, whether SORNA or state registration rules are unconstitutional. The Court noted that separate lawsuits could challenge SORNA or state law directly, but this case cannot proceed because it no longer presents a dispute the courts can resolve.

Dissents or concurrances

Three Justices would have sent the case back to the Ninth Circuit to consider whether the appeal was moot before deciding the merits; one Justice did not participate.