State laws have adequately protected the public for many years. This rule change would somehow subject people, whose state convictions no longer require them to register, whom judges have found adequately rehabilitated to permit them not to register under state law, to federal prosecution when they have completely complied with state law. There is no provision to give such people, who may have been convicted as juveniles, notice of this new threat of federal prosecution. This rule change thus violates the due process requirements of notice, and the states’ constitutional rights to address the community’s needs for protection from sex offenders. It is a bad proposal that will result in unjustly penalizing people who have satisfied their state court sentences and proceeded with their lives without posing a threat to anyone, even while the constitutionality is litigated in many courts. Please do not adopt these changes.

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