_{[145]      Final Guidelines, supra note 3, at 38,032 (“SORNA’s requirements are informational in nature and do not restrict where sex offenders can live.”); Supplemental Juvenile Guidelines, supra note 57, at 50,555 (“SORNA imposes no restrictions on where sex offenders may live.”); id. at 50,557 (“SORNA contains nothing that either prohibits or requires residency restrictions.”); Applicability of the Sex Offender Registration and Notification Act, 75 Fed. Reg. 81,849, at 81,851 (codified at C.F.R. § 72.3), www.govinfo.gov/content/pkg/FR-2010-12-29/pdf/2010-32719.pdf (hereinafter Final Retroactivity Rule) (“SORNA . . . does not prescribe limitations on sex offenders’ places of residence, locations, or activities.”).} 

_{[146]      See Ariz. Rev. Stat. § 13-3727 (prohibiting level 3 offenders who have been convicted of a dangerous crime against children from residing within 1,000 feet of a school or child care facility); Ark. Code Ann. § 5-14-128(a) (prohibiting level 3 and level 4 sex offenders from living within 2,000 feet of schools or day care centers); Cal. Penal Code § 3003(g) (prohibiting high-risk paroled sex offenders from residing within one-half mile of any school); Cal. Penal Code § 3003.5(b) (prohibiting sex offenders from residing within 2,000 feet of any public or private school, or park where children regularly gather); Cal. W&I Code § 6608.5(f) (prohibiting sexually violent predators who are conditionally released from living within one-quarter of a mile of any school); Del. Code Ann. tit. 11, § 1112 (prohibiting sex offenders from residing or loitering on or within 500 feet of any school); Fla. Stat. § 947.1405(7)(a)(2) (prohibiting sex offenders whose victim is under 18 years old from living within 1,000 feet of a school or where children congregate); Ga. Code Ann. § 42-1-15(b) (prohibiting any sex offender, on or after July 1, 2008, from residing within 1,000 feet of any child care facility, church, school, or areas where minors congregate if the commission of the act requiring registration occurred on or after July 1, 2008); Ga. Code Ann. § 42-1-17 (prohibiting any sex offender who committed an act between June 4, 2003, and June 30, 2006, for which they are required to register from residing within 1,000 feet of any child care facility, school, or area where minors congregate); Idaho Code § 18-8329 (prohibiting sex offenders from being within 500 feet of a school or day care or from residing within 500 feet of a school or day care); 720 Ill. Comp. Stat. § 5/11-9.3 (outlining additional restrictions prohibiting sex offenders from being within school zones and in other areas and prohibiting sex offenders from residing within 500 feet of a school or school property); Ind. Code § 11-13-3-4(g)(2)(B) (prohibiting sex offenders from residing within 1,000 feet of any school property for the duration of their parole); Iowa Code § 692A.114(2) (prohibiting sexual offenders from residing within 2,000 feet of a school or child care facility); La. Rev. Stat. § 14:91.1 (prohibiting sexually violent predators from being present on school property, school buses and from residing within 1,000 feet of a school, early learning center, playground, youth center, public swimming pool, or arcade); La. Rev. Stat. § 14:91.2 (prohibiting sex offenders, who are convicted of a sex offense or aggravated offense where the victim was under 13 years old, from being within 1,000 feet of a school, school buses, public park, early learning center, or public library and from residing within 1,000 feet of a school, early learning center, or public park); La. Rev. Stat. § 15:538 (prohibiting serious paroled sex offenders from going within 1,000 feet of a school, school buses, early learning center, playground, public swimming pool, youth center, or public arcade and from residing within 1,000 feet of a school, early learning center, playground, youth center, public swimming pool, or public arcade for the duration of parole or probation); Miss. Code Ann. § 45-33-25(4)(a) (prohibiting sex offenders from residing within 3,000 feet of property comprising any school, child care facility, residential child-caring agency, children’s group home or any playground, ballpark, or other recreational facility utilized by persons under the age of 18); Mo. Rev. Stat. § 566.147 (prohibiting certain sex offenders from residing within 1,000 feet of a school or child care facility); Mont. Code Ann. § 46-18-255 (requiring a judge sentencing a person convicted of a sexual offense involving a minor and designated as a level 3 offender, as a condition to probation, parole, or deferment or suspension of sentence, impose on the defendant restrictions on the defendant’s residency in the proximity of a private or public elementary or high school, preschool, licensed day care center, church, or public park); N.Y. Penal Law § 65.10(4-a) (prohibiting certain offenders from knowingly entering into or upon school grounds or any other facility or institution that is primarily used for the care or treatment of persons under the age of 18); Ohio Rev. Code Ann. § 2950.034 (prohibiting offenders from living within 1,000 feet of a school); Okla. Stat. Ann. tit. 57, § 590(A) (prohibiting registered sex offenders from residing within a 2,000-feet radius of a school); Or. Rev. Stat. §§ 144.642(1), 144.644(2)(a) (providing Department of Corrections with authority to determine where and how close a sex offender can live to a school or day care center); R.I. Gen. Laws Ann. § 11-37.1-10(c)-(d) (prohibiting level I and II offenders from living within 300 feet of public or private school property and high risk (level III) offenders from living within 1,000 feet of a school); S.C. Code Ann. § 23-3-535(B) (prohibiting offenders from living within 1,000 feet of a school, day care center, children’s recreational facility, park, or public playground); S.D. Rev. Code Ann. § 22-24B-23 (prohibiting offenders from residing within community safety zones); Tenn. Code Ann. § 40-39-211 (prohibiting offenders from residing within 1,000 feet of schools, child care facilities, or the victim); Texas Govt. Code § 508.187(b) (providing state Parole Board with authority to decide where and how close a paroled sex offender can live or go near to a child safety zone); Utah Code Ann. § 77-27-21.7 (prohibiting certain sex offenders from being in a “protected area” unless certain exceptions are met); see also People v. Superior Ct. of Santa Cruz Cnty., 303 Cal. Rptr. 3d 573 (Ct. App 2023) (unpublished decision) (holding that the “prohibition against releasing [a sexually violent predator or] an offender with a history of sexual conduct with children to a residence within a quarter mile of a school applies, even if the school commenced operation . . . only after the date of notice to the community [regarding the offender’s release]” and it also applies to home schools); In re T.B., 489 P.3d 752, 766 (Colo. 2021) (recognizing that “though Colorado imposes no statewide residency restrictions on sex offenders, individual municipalities may impose such restrictions”); Walker v. State, 860 S.E.2d 868, 872 (Ga. Ct. App. 2021) (holding that Georgia’s loitering prohibition, which prohibits sex offenders from loitering at any child care facility, school, or area where minors congregate, only applies to sex offenders who are required to register for acts that were committed after July 1, 2008); Lingnaw v. Lumpkin, 474 P.3d 274, 282 (Idaho 2020) (holding that sex offender’s property was within 500 feet of property on which a school is located and therefore, Idaho statute prohibiting sex offenders from residing within 500 feet of the property on which a school is located, applied to sex offender); State v. McCord, 621 S.W.3d 496, 500 (Mo. Apr. 6, 2021) (en banc) (affirming sex offender’s conviction for residing within 1,000 feet of a public school and noting that Missouri statute prohibiting sex offenders from residing within 1,000 feet of a school is applicable to institutions where instruction is given); Alvarez v. Annucci, 187 N.E.3d 1032, 1034 (N.Y. 2022) (holding that residency restrictions under New York’s Sexual Assault Reform Act apply equally to eligible sex offenders released on parole, conditionally released, or subject to a period of post-release supervision); People ex rel. E.S. v. Superintendent, Livingston Corr. Facility, 219 N.E.3d 353, 354 (N.Y. 2023) (holding that New York’s school grounds mandatory condition, which prohibits sex offenders from knowingly entering school grounds and is imposed on convicted sex offenders who have served a sentence for an enumerated offense and where the offender’s victim was under the age of 18 at the time of the offense or the offender is deemed a level 3 sex offender, is applicable to a person adjudicated as a youthful offender); People ex rel. Negron v. Superintendent, Woodbourne Corr. Facility, 160 N.E.3d 1266, 1269 (N.Y. 2020) (holding that N.Y. Executive Law § 259-c(14)’s school grounds restriction, which prohibits certain parolees from residing within 1,000 feet of a school, is only mandatory for level 3 sex offenders who are serving a sentence for an enumerated offense); People ex rel. McCurdy v. Warden, Westchester Cnty. Corr. Facility, 163 N.E.3d 1087, 1094 (N.Y. 2020) (holding that N.Y. Correction Law § 73(10) authorizes New York Department of Corrections and Community Supervision to place a sex offender in temporary housing at a residential treatment facility more than six months after his underlying term of imprisonment expires where the offender’s ability to secure approved residence, that was not within 1,000 feet of a school, was pending).}

_{[147]      “[L]aws restricting sex offenders’ proximity to schools or parks have been . . . upheld under rational basis review because courts have found they do not implicate the First Amendment or involve a fundamental right.” Doe v. Prosecutor, Marion County, Ind., 705 F.3d 694, 702 (7th Cir. 2013) (citingSmith v. Doe, 538 U.S. 84 (2003)) (holding that Alaska sex offender registration laws do not violate Ex Post Facto Clause); Conn. Dep’t of Pub. Safety v. Doe, 538 U.S. 1, 1-2 (2003) (holding that the public disclosure provision of Connecticut’s sex offender registration law did not violate the Due Process Clause); Doe I v. Miller, 405 F.3d 700, 715-16 (8th Cir. 2005) (holding residency restriction prohibiting sex offenders who commit sex crimes against minors from residing within 2,000 feet of school or child care facility constitutional under rational basis review).}

_{[148]      Doe v. City of Albuquerque, 667 F.3d 1111, 1135-36 (10th Cir. 2012) (affirming district court’s grant of summary judgment and holding that City of Albuquerque’s ordinance banning registered sex offenders from entering public libraries was not narrowly tailored and did not leave open ample alternative channels of communication and therefore does not constitute a permissible, time, place, or manner restriction under the First Amendment); McGuire v. Marshall, No. 19-CV-174, 2024 WL 2401833, at *42-43 (M.D. Ala. May 23, 2024), appeal filed, No. 24-11731 (11th Cir. May 28, 2024) (holding that Alabama’s residency restrictions are substantially overbroad on their face, are not narrowly tailored to the state’s interest in preventing sexual abuse, and violate the First Amendment).} 

_{[149]      Vazquez v. Foxx, 895 F.3d 515, 523 (7th Cir. 2018) (holding that amendment to Illinois’ statute, which prohibits sex offenders from living within 500 feet of day care homes, does not violate the Fifth Amendment’s Takings Clause); Doe v. Baker, No. 05-CV-2265, 2006 WL 905368, at *8-9 (N.D. Ga. Apr. 5, 2006) (holding that Georgia residency statute did not violate the Takings Clause); but see Mann v. Ga. Dep’t of Corr., 653 S.E.2d 740, 745 (Ga. 2007) (holding that Georgia statute prohibiting registered sex offenders from residing within 1,000 feet of a facility where minors regularly congregate without just and adequate compensation violates the Takings Clauses of the state and federal constitutions).} 

_{[150]      People v. Mosley, 344 P.3d 788, 794 (Cal. 2015) (addressing challenge under Apprendi and holding that residency restrictions are not punishment for the purposes of Sixth Amendment analysis and therefore offender had no right to a jury trial); People v. Presley, 156 Cal. App. 4th 1027, 1035 (2007) (holding that the public notification and residency requirements under California’s sex offender registration laws do not constitute punishment that would require jury findings under the Sixth Amendment).} 

_{[151]     Barnes v. Jeffreys, 529 F. Supp. 3d 784, 794 (N.D. Ill. 2021) (holding that Illinois’ one-per-address statute, which prohibits an individual who is on mandatory supervised release for a sex offense from living at the same address or in the same condominium/apartment unit or complex with another person the offender knows or reasonably should know is a convicted sex offender or who has been placed on supervision for a sex offense, constitutes cruel and unusual punishment in violation of the Eighth Amendment because it penalizes offenders’ homeless and indigent status and their failure to obtain acceptable housing is “involuntary conduct inseparable from their indigent or homeless status”).}

_{[152]      Doe #1 v. Cooper, 842 F.3d 833, 842-43 (4th Cir. 2016) (holding one portion of the state’s residency restriction provisions, prohibiting sex offenders from being present at “any place where minors gather for regularly scheduled educational, recreational, or social programs,” was unconstitutionally vague in violation of the Fourteenth Amendment’s Due Process Clause); Duarte v. City of Lewisville, 858 F.3d 348, 352-53 (5th Cir. 2017) (holding that, even if the city’s residency restriction, which prohibited sex offenders from living within 1,500 feet of locations where children commonly gather, infringed on a protected liberty interest, the offender was not entitled to a hearing to determine that he was not currently dangerous under the Fourteenth Amendment’s Due Process Clause); Millard v. Rankin, 265 F. Supp. 3d 1211, 1232, 1235 (D. Colo. 2017) (relying in part on certain localities’ residency restriction provisions in finding that Colorado’s registration scheme violated the Eighth and Fourteenth Amendments), rev’d sub nom. Millard v. Camper, 971 F.3d 1174 (10th Cir. 2020); Doe 1 v. Marshall, 367 F. Supp. 3d 1310, 1332 (M.D. Ala. 2019) (holding that Alabama’s residency restriction prohibiting sex offenders from living or working within 2,000 feet of a school or day care does not violate substantive due process); In re Taylor, 343 P.3d 867, 879 (Cal. 2015) (holding that blanket enforcement of California’s mandatory residency restriction, which prohibits registered sex offenders from residing within 2,000 feet of any public or private school, or park where children regularly gather, as applied to registered sex offenders on parole in San Diego County, is unconstitutional on due process grounds); People v. Pepitone, 106 N.E.3d 984, 994-95 (Ill. 2018) (holding that Illinois statute which prohibits certain sex offenders from knowingly entering or being present in public parks does not violate due process under the U.S. Constitution and Illinois Constitution); People v. Leroy, 828 N.E.2d 769, 776-77 (Ill. App. Ct. 2005) (holding Illinois statute prohibiting child sex offenders from living within 500 feet of a school was constitutional and did not violate due process); People ex rel. Johnson v. Superintendent, Adirondack Corr. Facility, 163 N.E.3d 1041, 1053 (N.Y. 2020) (holding that the temporary confinement of sex offenders in correctional facilities, while on a waiting list for legally compliant housing, is rationally related to a conceivable, legitimate government purpose of keeping level 3 sex offenders more than 1,000 feet away from schools, and therefore is constitutional), cert. denied, sub nom. Ortiz v. Breslin, 142 S. Ct. 914 (2021) (Sotomayor, J., statement respecting denial of certiorari) (writing, “[a]lthough [offender’s] petition does not satisfy this Court’s criteria for granting certiorari,” “to emphasize that New York’s residential prohibition, as applied in New York City, raises serious constitutional concerns” and that “New York should not wait for this Court to resolve the question whether a State can jail someone beyond their parole eligibility date, or even beyond their mandatory release date, solely because they cannot comply with a restrictive residency requirement”); State v. Collier, No. W2019-01985-CCA-R3-CD, 2021 WL 142172, at *1 (Tenn. Crim. App. Jan. 14, 2021) (holding that Tennessee law, which prohibits sex offenders from being within 1,000 feet of any playground, recreation center, or public athletic field, when children under 18 years of age are present and when they do not have any other specific or legitimate reason for being there, did not violate the Due Process Clause of the Fourteenth Amendment because the definition of “playground,” while not defined, held its common and ordinary meaning and therefore was not ambiguous or vague).}

_{[153]      Castaneira v. Potteiger, 621 F. App’x 116, 119 (3d Cir. 2015) (holding that sex offender parolee “was not similarly situated to Pennsylvania offenders because Georgia, not Pennsylvania, imposed the special [1,000 feet residency restriction]” and therefore there was no violation of equal protection); Barnes, 529 F. Supp. 3d at 799 (holding that Illinois’ one-per-address statute “creates an illegal classification based on wealth which deprives Plaintiffs of their liberty as a result of their inability to pay” in violation of the Fourteenth Amendment’s right to equal protection because it treats wealthy sex offenders differently from those who are poor and deprives homeless and indigent offenders of conditional liberty on mandatory supervised release, and therefore, the defendant’s application of the statute “creates an illegal classification based on wealth which deprives Plaintiffs of their liberty as a result of their inability to pay”); Leroy, 828 N.E.2d at 778 (holding Illinois statute prohibiting child sex offenders from living within 500 feet of a school was constitutional and did not violate equal protection).}

_{[154]     State v. Willard, 756 N.W.2d 207, 212 (Iowa 2008) (holding that Iowa statute prohibiting sex offender from living within 2,000 feet of a school was not an illegal bill of attainder).}

_{[155]     Groys v. City of Richardson, No. 20-cv-03202, 2021 WL 3852186, at *5-7 (N.D. Tex. Aug. 9, 2021) (holding that City of Richardson’s ordinance prohibiting sex offenders who appear on the Texas sex offender registry from living within 2,000 feet of any premises where children commonly gather is not punitive and therefore cannot violate the Ex Post Facto Clause); Koch v. Village of Hartland, 43 F.4th 747 (7th Cir. 2022) (holding that the Village of Hartland’s ordinance is retroactive and the critical question in determining whether a law is retroactive, so as to violate the Ex Post Facto Clause, is whether the law changes the legal consequences of acts completed before its effective date, not whether the law targets only conduct occurring after the law’s enactment, and remanding to consider the punitive prong); Weems v. Little Rock Police Dep’t, 453 F.3d 1010, 1014 (8th Cir. 2006) (holding that Arkansas Sex Offender Registration Act’s residency restrictions do not violate the Ex Post Facto Clause); Doe I v. Miller, 405 F.3d 700, 723 (8th Cir. 2005) (holding that Iowa residency restriction, which prohibits individuals who have committed a criminal sex offense against a minor from residing within 2,000 feet of a school or child care facility, is not unconstitutional on its face and does not amount to an unconstitutional ex post facto punishment); Doe 1 v. City of Apple Valley, 487 F. Supp. 3d 761, 774 (D. Minn. 2020) (holding that City of Apple Valley’s ordinance, which prohibits certain sex offenders from residing within 1,500 feet of schools, child care centers, places of worship, and parks, including offenders who have committed a “designated sexual offense” against a child under the age of 16; offenders who are required to register as a predatory offender as a result of having committed an offense against a child under the age of 16; or offenders who have been categorized as a level III sex offender, regardless of the age of the offender’s victim, does not violate the Ex Post Facto Clause); McGuire v. Marshall, 50 F.4th 986, 1016 (11th Cir. 2022) (holding that Alabama’s residency restriction, which limits the total number of hours a sex offender can spend in any one place during a given month, is not “so punitive in purpose or effect that [it] override[s] the Alabama legislature’s stated nonpunitive intent” and retroactive application does not violate the Ex Post Facto Clause); People ex rel. Rivera v. Superintendent, Woodbourne Corr. Facility, 221 N.E.3d 1, 13 (N.Y. 2023) (holding that retroactive application of New York’s school grounds condition, which prohibits level 3 sexually violent offenders from residing within 1,000 feet of school grounds, to offender did not violate the Ex Post Facto Clause of the U.S. Constitution); but see Does 1-35 v. State ex rel. Ford, No. 15-cv-01638, 2020 WL 5820992, at *6 (Sept. 29, 2020) (holding that Nevada’s movement and residency restrictions under Nev. Rev. Stat. § 213.1243, as applied to the plaintiffs, who committed criminal offenses before the restrictions were added, are retroactive and punitive because the restrictions increase the risk of additional punishment to plaintiffs for their crimes, only apply to tier III offenders, are a restraint on the plaintiffs’ liberty, meet the goals of punishment in that they are retributive and have a deterrent effect, and are unreasonable, and, as a result violate the Ex Post Facto Clause and permanently enjoining the defendants from retroactively enforcing any condition of lifetime supervision not specifically set forth in § 214.1243 before Oct. 1, 2007, to any plaintiffs whose last relevant criminal offense, including any offense that would trigger the movement and residency restrictions, occurred prior to Oct. 1, 2007), vacated in part by 2021 WL 4509163, at *3 (D. Nev. Sept. 30, 2021) (holding that retroactive application of Nevada’s residency and movement restrictions to offenders who committed criminal offenses prior to Oct. 1, 2007, violates the Ex Post Facto Clause); Doe v. Miami-Dade County, 846 F.3d 1180, 1186 (11th Cir. 2017) (holding that homeless sex offenders sufficiently alleged that Miami-Dade County’s child safety ordinance, which prohibits individuals convicted of certain sex offenses where the victim is under 16 years of age from residing within 2,500 feet of any school, was so punitive to violate the Ex Post Facto Clauses of the federal and Florida Constitutions); Commonwealth v. Baker, 295 S.W.3d 437, 447 (Ky. 2009) (holding that retroactive application of Kentucky’s residency restrictions, which were punitive and exceeded the nonpunitive purpose of public safety, violated the Ex Post Facto Clauses of the state and federal constitutions).} 

_{[156]     State v. Stark, 802 N.W.2d 165, 171 (S.D. 2011) (holding that South Dakota statutes prohibiting sex offenders from loitering in a community safety zone were not unconstitutionally vague).}

_{[157]     Doe v. City of Lynn, 36 N.E.3d 18, 23 (Mass. 2015) (holding that municipal ordinance, imposing residency restrictions on sex offenders, was unconstitutional under state’s Home Rule Amendment and preempted by state law); People v. Diack, 26 N.E.3d 1151, 1158 (N.Y. 2015) (holding that county was preempted by New York law from enacting residency restrictions, prohibiting registered sex offenders from residing within 1,000 feet of a school); G.H. v. Twp. of Galloway, 951 A.2d 221, 231 (N.J. Super. Ct. App. Div. 2008) (holding that municipal ordinances prohibiting convicted sex offenders from living within a designated distance of schools, parks, playgrounds, and day care centers, was preempted by New Jersey law); but see Ryals v. City of Englewood, 364 P.3d 900, 910 (Colo. 2016) (holding that local ordinance, “which effectively bars certain sex offenders from residing within the city,” did not conflict with state law and therefore was not preempted by state law).}

_{[158]     Valenti v. Lawson, 889 F.3d 427, 430-32 (7th Cir. 2018) (holding that Indiana residency restriction, prohibiting serious sex offenders from knowingly or intentionally entering school property, was rationally related to a legitimate purpose and therefore did not violate the state constitution, even though offender argued it interfered with his right to vote because his polling place was at a high school and he was prohibited from being on school property).}

_{[159]     United States v. King, 431 F. App’x 630, 632-33 (10th Cir. 2011) (holding that Oklahoma’s residency restrictions, prohibiting sex offenders from living within 2,000 feet of facilities whose primary purpose is working with children, did not present an obstacle to complying with federal sex offender registration requirements); People v. Legoo, 178 N.E.3d 1110, 1117 (Ill. 2020) (affirming conviction under 720 Ill. Comp. Stat. § 5/11-9.4-1(b) and holding that 720 Ill. Comp. Stat. § 11-9.4-1(b) completely bars certain sex offenders from being present in public parks and the exception to criminal liability in § 11-9.3(a-10) does not apply); State v. Russell, No. W2019-01874-CCA-R3-CD, 2020 WL 5033435, at *4 (Tenn. Crim. App. Aug. 25, 2020) (holding that there was sufficient evidence to sustain conviction for violating sex offender residency restriction prohibiting offender from “being alone” with a minor in a private area where minor was in the defendant’s home).} 

_{[160]      Supplemental Juvenile Guidelines, supra note 57, at 50,556 (“SORNA imposes no restrictions on registrants’ qualification for employment or on unsupervised association with younger children.”).}

_{[161]      See, e.g., Ala. Code § 15-20A-13(a) (prohibiting adult sex offenders from maintaining employment or volunteering at any school, child care facility, mobile vending business that provides services primarily to children, or any other business or organization that primarily provides services to children, or any amusement or water park); Ala. Code § 15-20A-31(a) (prohibiting juvenile sex offenders from working or volunteering at any school, child care facility, or other business or organization that provides services primarily to children); Ark. Code Ann. § 12-12-929(b) (prohibiting certain sex offenders from holding a position of public trust); Fla. Stat. §§ 435.06, 435.07(4)(b) (disqualifying individuals who are registered as sex offenders from being eligible for certain types of employment); Ga. Code Ann. § 42-1-15(c)(1) (prohibiting any sex offender, on and after July 1, 2008, from being employed or from volunteering at any child care facility, school, or church, or by or at any business or entity that is located within 1,000 feet of a child care facility, school, or church if the commission of the act requiring registration occurred on or after July 1, 2008); Ga. Code Ann. § 42-1-15(c)(2) (prohibiting any sexually dangerous predator, on or after July 1, 2008, from being employed or from volunteering at any business or entity that is located within 1,000 feet of an area where minors congregate if the commission of the act requiring registration occurred on or after July 1, 2008); Ga. Code Ann. § 42-1-16(c)(1) (prohibiting any sex offender, who committed an act between July 1, 2006, and June 30, 2008, requiring registration, from being employed by any child care facility, school, or church, or by or at any business or entity that is located within 1,000 feet of a child care facility, school, or church); Ga. Code Ann. § 42-1-16(c)(2) (prohibiting any sexually dangerous predator, who committed an act between July 1, 2006, and June 30, 2008, requiring registration, from being employed by any business or entity that is located within 1,000 feet of an area where minors congregate); Idaho Code § 18-8327 (prohibiting sex offenders from applying for or accepting employment at a day care center, group day care facility, or family day care home); Iowa Code § 692A.113 (prohibiting sex offenders convicted of a sex offense against a minor from being employed or volunteering at any municipal, county, or state fair or carnival when a minor is present, arcade or amusement centers, public or nonpublic schools, child care facilities, public libraries, recreational/sports areas, swimming pools, or ice cream trucks); Iowa Code § 692A.115 (prohibiting sex offenders from working at facilities providing care to vulnerable adults); Mont. Code Ann. § 46-18-255 (requiring a judge sentencing a person convicted of a sexual or violent offense impose, as a condition to probation, parole, or deferment or suspension of sentence impose reasonable employment prohibitions and restrictions designed to protect the class of persons containing the likely victims of further offenses by the defendant); N.C. Gen. Stat. § 14-208.17 (prohibiting sex offenders from working or volunteering at any place where a minor is present and the person’s responsibilities or activities would include instruction, supervision, or care of a minor or minors); see alsoDoe v. Settle, No. 20-cv-190, 2020 WL 5352002, at *6 (E.D. Va. Aug. 17, 2020) (holding that there is no right to employment in a particular profession, and the restrictions on employment provided by Virginia’s registry laws, which prohibit teaching children, operating a day care, working for a rideshare, and operating a tow truck, are reasonable), aff’d, 24 F.4th 932 (4th Cir. 2022).}

_{[162]      For example, if a person has been convicted of a sex offense involving children, their certified shorthand reporter’s license or amateur radio license may be revoked. Sonntag v. Stewart, 53 N.E.3d 46, 52 (Ill. App. Ct. 2015) (revoking reporter’s license as sanction for conviction of possession of child pornography); In re Titus, 29 FCC Rcd. 14066 (2014) (reversing administrative law judge’s decision and revoking convicted sex offender’s amateur radio license). Additionally, an attorney convicted of a sex offense may also be disbarred indefinitely. Toledo Bar Ass’n v. Long, 179 N.E.3d 1262, 1264 (Ohio 2021) (per curiam) (holding that the defendant, a licensed attorney in Ohio who was convicted of multiple sex offenses, should be indefinitely suspended from the practice of law). But see In re Stevens, 519 P.3d 208, 225-26 (Wash. 2022) (holding that offender convicted of voyeurism who is required to register as a sex offender is of good moral character and should be admitted to practice law in Washington).} 

_{[163]     See, e.g., Ga. Code Ann. § 42-1-14 (requiring sexually dangerous predators, as determined by risk assessment, to report in person six months after their birthday); Mass. Gen. Laws ch. 6, § 178K (utilizing risk assessments to determine level of notification for sex offenders), Mont. Code Ann. § 46-23-506 (outlining sex offenders’ registration duration and frequency requirements based on assigned risk level), N.Y. Correct. Law § 168-h (utilizing risk assessments to determine sex offenders’ registration duration and frequency); see also Doe (No. 496501) v. Sex Offender Registry Bd., 126 N.E.3d 939, 954 (Mass. 2019) (noting that an offender is “generally unlikely to pose a moderate degree of dangerousness—and thus to qualify as a level two sex offender—where his or her risk of reoffense relates only to noncontact offenses that do not put a victim in fear of bodily harm by reason of a contact sex offense”); Doe (No. 7083) v. Sex Offender Registry Bd., 35 N.E.3d 698, 708 (Mass. 2015) (holding that a sex offender’s liberty interests were violated where he was classified as a level 3 sex offender 10 months prior to his earliest parole eligibility date and noting that “a final classification must be based on an evaluation of the offender’s risk of reoffense at a time reasonably close to the actual date of discharge” in order to satisfy due process); Doe (No. 972) v. Sex Offender Registry Bd., 697 N.E.2d 512, 513 (Mass. 1998) (holding that the board must hold an evidentiary hearing to prove the appropriateness of an offender’s risk classification before requiring the offender to register as a sex offender), overruled by Doe (No. 380316) v. Sex Offender Registry Bd., 41 N.E.3d 1058 (Mass. 2015); State v. Williams, 952 N.E.2d 1108, 1112 (Ohio 2011) (holding that offenders who committed their offenses prior to Jan. 1, 2008, are entitled to a court hearing to determine the offenders’ risk level or classification and then, offenders’ classification is used to establish the offenders’ registration duration and frequency requirements); State v. Decredico, No. PM-2018-2467, 2021 WL 2324187, at *9 (R.I. Sup. Ct. June 1, 2021) (holding that there was competent evidence to support the board’s classification of the defendant as a level II sex offender where the board relied on the STABLE-2007, a validated risk-assessment tool), vacated and remanded by 291 A.3d 544, 550 (R.I. 2023) (holding that there was insufficient evidence to support the board’s moderate risk classification of offender convicted of possession of child pornography as a level II sex offender where the board relied on the STABLE-2007 because the STABLE-2007 has not been validated for noncontact offenders); In re Christopher H., 854 S.E.2d 853, 856 (S.C. Ct. App. 2021) (holding that sentencing court erred by finding good cause existed to place juvenile on sex offender registry where there was insufficient evidence showing he was at risk of reoffending), cert. dismissed, 873 S.E.2d 773 (S.C. 2022). But see Spencer v. State Police Dir., No. 352539, 2020 WL 6814649, at *7-8 (Mich. Ct. App. Nov. 19, 2020) (per curiam) (holding that the lack of an individualized assessment of each particular sex offender’s actual dangerousness does not make Michigan’s Sex Offender Registration Act unconstitutional).}

_{Some jurisdictions also utilize risk assessments in determining the eligibility of offenders to modify or terminate their registration requirements. See, e.g., Ga. Code Ann. § 42-1-19 (requiring risk assessment be completed prior to court considering a petition for release); Iowa Code § 692A.128 (requiring risk assessment be completed before court will determine whether an offender’s petition for reduction of registration period will be granted), N.Y. Correct. Law § 168-o(2) (utilizing risk assessment in determining offenders’ eligibility to petition for relief from registration); Or. Rev. Stat. § 163A.105 (requiring risk assessment be performed on offenders when convicted of specific crimes and sentenced to a term of imprisonment and before being placed on supervision, probation, etc.); see also Becher v. State, 957 N.W.2d 710, 716-17 (Iowa 2021) (reversing district court’s denial of offender’s application for modification of his registry requirements, noting that the district court erred in considering offender’s STATIC-99R evaluation out of context and penalizing him for his years of successful adjustment to sex offender registration, and holding that adult sex offenders must be classified as low risk using standard risk assessment tools in order to modify their sex offender registration requirements); Fortune v. State, 957 N.W.2d 696, 706-10 (Iowa 2021) (outlining the proper framework for considering modification applications indicating that, once the threshold statutory requirements have been met (i.e., successful completion of sex offender treatment, requisite time on the registry, and a low-risk evaluation), the court should consider “only those factors that bear on whether the applicant is at low risk to reoffend and there is no substantial benefit to public safety in extending the registration requirements,” and that the “threat to public safety must be tied to the individual applicant and the record established in the case”).}  

_{[164]      See, e.g., Ga. Code Ann. § 42-1-14 (requiring sexually dangerous predators, as determined by risk assessment, to wear electronic monitoring system); Iowa Code § 692A.124 (utilizing risk assessment to determine whether sex offender will be subject to electronic tracking and monitoring); S.C. Code Ann. § 23-3-540 (requiring electronic monitoring of certain sex offenders based upon their assigned risk level).}

_{[165]      See, e.g., Ala. Code § 15-20A-26 (requiring juvenile sex offender undergo risk assessment following completion of treatment to determine offender’s risk to the community and level of notification that will apply), Me. Rev. Stat. tit. 34-A, § 11253 (requiring risk assessment be applied to each registrant for purposes of notification to law enforcement agencies and the public); Me. Rev. Stat. tit. 34-A, § 11254 (requiring information about sex offenders, including the “status of the registrant when released as determined by the risk assessment” and an offender’s risk assessment score, be provided to the Department of Public Safety when offenders are conditionally released or discharged); Me. Rev. Stat. tit. 34-A, § 11256 (utilizing risk assessment for purposes of notification to the public regarding offenders’ conditional release or discharge); Neb. Rev. Stat. § 29-4013 (relying on risk assessment and a sex offender’s risk of recidivism in determining level of community notification); N.J. Stat. Ann. § 2C:7-13(2)(b) (utilizing risk assessments in determining what information to include on the public sex offender registry); Or. Rev. Stat. § 163A.215 (utilizing risk assessments to determine who to include on the sex offender registry); R.I. Gen. Laws Ann. § 11-37.1-6(1)(c) (requiring offenders who have a duty to register to be referred to the board “for a determination as to the level of risk an offender poses to the community” to determine offender’s community notification level); Tex. Crim. Pro. § 62.005 (permitting the department to include sex offender’s risk level on public registry website); Tex. Crim. Pro. § 62.007 (requiring that the Texas Department of Criminal Justice establish a risk assessment committee to develop a screening tool for sex offenders and permitting disclosure of an offender’s assigned risk level to the public); Tex. Admin. Code § 380.8787 (requiring sex offender risk assessment for sex offenders in the custody of the Texas Juvenile Justice Department); 13 Vt. Stat. Ann. § 5411b (requiring that the Department of Corrections evaluate sex offenders for purposes of determining whether they are “high risk” and who to include on the public registry); see also State v. Trujillo, 462 P.3d 550, 561 (Ariz. 2020) (recognizing that Arizona’s community notification provisions only apply to sex offenders who have been identified as high risk); State v. Henry, 228 P.3d 900, 907 (Ariz. Ct. App. 2010) (recognizing the nonpunitive purposes for sex offender and notification laws and to serve the “nonpunitive ends” of the registration statutes, the legislature has limited “mandatory community and website notification” to “offenders deemed to pose a heightened risk to the community”); Ariz. Dep’t of Pub. Safety v. Superior Ct. in and for Maricopa Cnty., 949 P.2d 983, 992 (Ariz. Ct. App. 1997) (holding that Arizona’s community notification provisions were not excessive because “the community-notification statute is sensitive concerning the varying degrees of risk presented by different offenders by tailoring the dissemination of information to the jeopardy posed”).}