Missouri Court of Appeals, Eastern District / Jun 7, 2022
Brock Smith, Appellant, vs. St. Louis County Police, et al., Respondent.
Brock Smith, a Tier I sex offender, sought removal from the Missouri Sex Offender Registry after fulfilling the ten-year registration period under the 2018 amendments to MO-SORA. The circuit court denied his petition, concluding that his federal registration requirement under SORNA mandated lifetime registration in Missouri, based on prior appellate interpretations. The Eastern District reversed, holding that the 2018 amendments fundamentally altered the registration framework, allowing Tier I and II offenders to petition for removal after the appropriate time, thereby superseding earlier interpretations that imposed lifetime registration.