Anderson v. Holder, Jr., et al.

In 1988, defendant was convicted of assault with intent to commit rape while armed; assaulting, resisting or interfering with a police officer with a dangerous weapon; and two counts of first-degree burglary while armed. Defendant was sentenced to prison for 18 years to life and while defendant was in prison, the District of Columbia enacted the Sex Offender Registration Act (SORA), D.C. Code 22-4001 to -4017. Defendant challenged SORA under various provisions of the U.S. Constitution, most notably the Ex Post Facto Clause. The court held that, like the sex offender registration requirement in Smith v. Doe, SORA's registration requirement did not violate the Ex Post Facto Clause where neither the Council of District Columbia's intent nor SORA's effects were so punitive as to render SORA a form of punishment. The court also held that defendant failed to show that he was entitled to relief in regards to his Fifth Amendment claims. The court further rejected defendant's Eighth Amendment and equal protection claim and defendant's claim under the D.C. Human Rights Act. Accordingly, the judgment of the district court was affirmed.