I am greatly concerned about the change regarding how a registrant is to update work and/or school information. While it may work for someone whose employer or school is nearby, it fails to take into account those who telework and distance learn. For example, suppose I’m born and raised in Hawaii (HI), have never left the State, and have no desire to ever leave the State. Further suppose I get hired to telework for a company wholly based in Minnesota (MN), and I enroll for online-only courses with a university in Florida (FL). Under the current rules, I report the MN employer and FL enrollment to the HI officials and I’m done. Easy, simple, and done.

Under this proposal, I’ll now be required to fly from HI to MN report in-person that I’ve been hired by a MN company. I’ll also then have to travel (probably by air again) to FL to report in-person that I have enrolled at a FL university. Aside from the expense this will incur, there’s a pretty good chance I may miss the reporting deadline of MN and/or FL. Beyond that, now that I’ve made a physical presence in FL, I will have to register with FL and be on its registry–for life. All I wanted to do was live my life out in HI while earning money (from MN) and getting an education (from FL) online. Instead, these rules impose an affirmative disability on me and compel me to make transcontinental travels to accomplish…what?

In addition to all of the above, the compulsion to travel to MN and FL will put many unsuspecting people in the proximity of an ex-sex-offender who previously has self-isolated in HI! Assuming, arguendo, I truly am a risk, these rules will now take me from HI, place me in MN and FL where nobody knows me and I can sneak around mostly unnoticed, just to accomplish an administrative task that’s currently managed by HI. This is completely counterproductive to the stated purpose of SORNA and its ilk. There is no gain in information by my reporting it in person in MN and FL versus HI reporting it electronically. If I’m going to choose not to report employment and/or schooling now, what makes anyone think I report them if I have to spend money and travel to do it? This makes no sense. All that happens is a (now disgruntled) registrant will be temporarily roaming undetected in communities who have no knowledge of him.

A similar example: suppose I live WA and work for a trucking company in WA. My employer gets bought by a Houston, TX, firm and moves all operations to Houston. As this is now a change in employment information, this proposal will now compel me to hie myself to Houston to report the information in-person. What is the benefit of this? Right now I can simply provide WA, WA tells TX and the Feds, and all is fine and done. I cannot for the life of me comprehend how forcing a registered offender to make long interstate travels does anything for further the stated goals of SORNA. It actually does the opposite!

While I applaud the clarifications this proposal accomplishes, the reporting requirements regarding employment and schooling are onerous, burdensome, and perhaps unconstitutionally disabling. These in-person employment and schooling reporting requirements seem designed purely 1) to trip up registrants, and/or 2) dissuade registrants from working or going to school anywhere beyond a short commute. That’s both wrong and shameful.