On June 24, 2013, the Supreme Court of the United States decided United States v. Kebodeaux, No. 12-418, holding that the registration requirements of the Sex Offender Registration and Notification Act (SORNA) that require convicted federal sex offenders to register as sex offenders in the states where they live, study, and work, even though they have already completed their sentences, is a valid exercise of Congress' authority under the Necessary and Proper Clause of the Constitution. The Court observed that when Kebodeaux was released from prison after being convicted in a special court-martial of a federal sex offense, he was subject to the registration requirements of the Jacob Wetterling Crimes Against Children and Sexually Violent Offender Registration Act, which was enacted under the Military Regulation Clause and the Necessary and Proper Clause. SORNA simply modified the registration requirements to which Kebodeaux was already subject, and those changes were "necessary and proper" means to further Congress' registration ends.

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