One of these laws is not like the others

On March 5, 2003, the United States Supreme Court, in Smith v. Doe1 (“Smith”) and Connecticut Department of Public Safety v. Doe2 (“DPS”) held that the Alaska3 and Connecticut4 sex offender registry and notification statutes were constitutional. The two state statutes were relatively modest with small penalties for failing to register and subjected to a limited review by the Court.5 At the time of the two Court decisions all fifty states had enacted sex offender registry and notification statutes (“Megan’s Laws”6).7 The Supreme Court opinions seemingly sanctified the laws of the states and ensured that registries would remain a permanent fixture of America’s sex offender policy.

One of these is not like the others

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