United States v. Juvenile Male

Background

A now-adult man was adjudicated delinquent after sexually abusing a 10-year-old boy beginning at age 13 and was sentenced to juvenile detention and supervision until age 21. While he was still in custody, Congress enacted SORNA, a law requiring certain sex offenders to register. At the Government’s request, the district court imposed a special condition that he register during his federal juvenile supervision. He appealed that condition to the Ninth Circuit, but he turned 21 while the appeal was pending and the federal supervision expired before the Ninth Circuit ruled.

Reasoning

The Court considered whether the Ninth Circuit could decide the case when the challenged condition had already ended. Article III requires a live dispute that a court decision is likely to fix. The Supreme Court asked the Montana Supreme Court whether state law required him to stay on the state registry only if the federal condition remained valid. Montana replied that its registration duty is independent of the federal supervision order. Because vacating the expired federal condition would not remove his state registration, the Court concluded there was no redress and the appeal was moot. The Court vacated the Ninth Circuit’s decision and remanded with instructions to dismiss the appeal.

Real world impact

The ruling warns courts not to decide the merits of challenges when a sentence or condition has ended and a favorable ruling would not remove concrete harms. People adjudicated as juveniles may nonetheless remain subject to separate state registration duties even if federal supervision is invalidated. The decision does not finally resolve all challenges to SORNA itself, and separate preenforcement or other lawsuits could proceed.

Dissents or concurrances

Three Justices said the case should be sent back to the Ninth Circuit so that court could consider mootness in the first instance rather than the Supreme Court deciding the question.