Derrick Maurice Carr Missouri Cases

Derrick Carr appealed the circuit court's dismissal of his petition to be removed from the Missouri Sex Offender Registry. The circuit court had determined Carr was a Tier III sex offender under the federal Sex Offender Registration and Notification Act (SORNA), requiring lifetime registration. The appellate court reversed, holding that the circuit court erred by applying a "circumstances-specific" approach instead of the "categorical approach" to determine Carr's tier, and that Carr was not a Tier III offender. Furthermore, the court found Carr was never subject to a SORNA registration obligation because his registration period expired before SORNA became applicable to pre-enactment offenders.