'When The House of Justice Is Deaf, Mute, And Blind'
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The case of Michel Moll, the internal policies of Sheriff Jim Arnott, and the 2023 ruling by the Missouri Supreme Court, all demonstrate that we have reached a boiling point in the way state sex offender registration and notification laws are operating and being enforced. And everyone pays the price, when the house of justice is deaf, mute, and blind.
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'When The House of Justice Is Deaf, Mute, And Blind'
- 1. 'WHEN THE HOUSE OF JUSTICE IS DEAF, MUTE, AND BLIND' The case of Michel Moll, the internal policies of Sheriff Jim Arnott, and the 2023 ruling by the Missouri Supreme Court, all demonstrate that we have reached a boiling point in the way state sex offender registration and notification laws are operating and being enforced. And everyone pays the price, when the house of justice is deaf, mute, and blind. Christopher Cross, President Missouri Guardianship Association Duly court appointed legal guardian Secretary of State Participant #430039 P.O. Box 1409 Jefferson City, Missouri 651 02 Legal_G ua rdian7 7 @ya h oo. com ' .'t::r.
- 2. CASE STUDY Court records show that on June 4, 2A24, Mr. Michel Moll was sentenced to 1S0-years in state prison. Mr. Moll was convicted of his sex offense in 1986. Thereafter, Mr. Moll was convicted of having committed five separate Counts of failing to register, as a sex offender in Missouri. The Court sen- tenced Mr. Moll to a maximum prison term of thirty-years on each separate Count. Moreover, the Court ordered that he serve each thirty-year prison sentence consecutive to the others, rather than ordering that each term run concurrent. As such, the Court imposed the harshest sentence against Mr. Moll. The felony information sheet filed by the MissouriAttorney General points out that a defendant who commits a third offense of failing to registered is subject to a mandatory minimum of two-years in prison. The felony information sheet asserts Mr. Moll committed five offenses in that of failing to regis- ter two address, one telephone number, on change of vehicle information and completing his 90-day registration. As such, pursuant to the felony information sheet, Mr. Moll was subject to a total minimum period of ten years in prison for all five offenses. The judge, however, sentenced Mr. Moll to 3O-years on each offense committed, for the combined total of 150-years in prison. The felony information sheet shows that on December 20,2021, Mr. Moll registered as a sex offender in Missouri. The information sheet asserts that Mr. Moll failed to register his moving to a new address within three business days, sometime between January 1, 2A22 to January 31, 2022, which is Count l. The information sheet asserts in Count ll, that on April 1, 2022, Mr. Moll failed to register his change in vehicle information. Count lll asserts that sometime between February 2O22lo April2022, Mr. Moll failed to register a second new address. The information sheet asserts in Count lV Mr. Moll failed to report for his 90-day registration period on March 16,2A22. And Count lV asserts that Mr. Moll failed to register a new telephone number in his 90-day registration period, on March 16,2022. The felony information sheet shows Mr. Moll committed all five offenses within three months of his becoming registered in Missouri. Thus, giving a mitigating factor that Mr. Moll may not have been aware of or he did not fully understand all reporting requirements in Missouri, given the close nexus or casual connection between the dates of all the events. The felony information sheet does not assert in any Count, that any time from December 20,2021 to March 16, 2022, Mr. Moll committed additional sex crime offenses. Thus, also showing a mitigating factor that Mr. Moll's offenses were not committed with purpose to commit further sex crime(s). ln the letter Mr. Moll filed with the court on January 1,2024, Mr. Moll pointed out in Fact # 8, on p.10, that as of that date, Mr. Moll had been in jail for just short of two-years and thereby asserting his requested right to a speedy trial had been violated numerous times. According to Mr. Moll's letter, a trial could have occurred three times within the time period that Mr. Moll was in jail. The court docket shows that numerous times, Mr. Moll's attorney requested and the trial court granted numerous contin- uances of the case. Given Mr. Moll's claims, it is likely the continuances were to benefit his attorney. On May 1, 2023, Mr. Moll fited a pro se Motion to Dismiss. The Court did not call up the motion to be heard, argued and ruled on until February 2,2024 and thus, not until nine months after Mr. Moll filed his pro se motion with the court. The judge denied Mr. Moll's motion without a written opinion. On February 2, 2024, Mr. Moll's attorney filed a Motion to Dismiss. The argument asserted that because Mr. Moll was convicted of his sex offense in 1986, the requirement in Missouri to register as a sex offender is a nullity, ultra yires and void ab initiobecause the requirement for Mr. Mollto register is a violation of his rights underArticle l, $ 13 of the Missouri Constitution, citing Squaw Creek Drainage Dist. v. Turney,138 S.W 12, Mo. 1911 and Doe v. Phillips,194 S.W.3d 833, 850, (Mo. banc 2006), which prohibit retrospective application of sex offender laws to person's convicted prior to 1995. This motion was also denied.
- 3. On February 7,2A24, the MissouriAttorney General filed a Memorandum on the Sovereign Cit- izenship claim Mr. Motl is alleged to have asserted to claim that he is exempt from having to register. ln the State's Memorandum, and without a trial on the claims, allegations and facts, the State as- serted the Sovereign Citizenship claim the State alleges, makes Mr. Moll anti-governrnent, based on the 2010 report by the Federal Bureau of lnvestigations on sovereign citizenship theories. Alleging that Mr. Moll is some anti-government fanatic or terrorist is to say, extremely prejudicial especially when Mr. Moll's claim of being exempt from the laws of the United States, specifically in that of the federal Sex Offender Registration and Notification Act, was asserted against his obligation to register pursuant toArticle l, S 13 of the Missouri Constitution prohibiting retroactively applying the law ln the court sentencing Mr. Moll not only to thirty-years in prison for each individual Count filed against Mr. Moll, but also ordering that each 3O-year sentence run consecutive to all other 3O-year sentences, one has to wonder if the Court acted on extreme prejudice against Mr. Moll because of the MissouriAttorney General's claim that Mr. Moll is some anti-govemment fanatic or terrorist for having pleaded he is exempt from the state and federal statutory laws requiring him to register. Suffice to say, the Courts' sentencing and subsequent order on the sentencing is the harshest punishment the Court could impose. On March 7,2024, Mr. Moll filed his second pro se Motion to Dismiss, consisting of thi(y-eight pages. Mr. Moll again asserted his right against the requirement to register because at the time that he was convicted of his sex crime in 1986, there was no statutory requirement for him to register. Mr. Moll asserted that where there is no statutory obligation to register then there is no criminal violation com- mitted for failing to register. Mr. Moll's pro se motion also cites Doe v. Phillips,194 S.W.3d 833. Mr. Moll also points out that in Doe, the Missouri Supreme Court asserted that Missouri enacted its sex of- fender registration laws to obtain or retain federal funding. The federal Sex Offender Registration and Notification Act stipulates certain federal funding will be withheld if a state does not create sex offender registration and notification laws. Mr. Moll brings up an interesting legal argument that, for all practical and perhaps legal pur- poses is related to the current lawsuit filed in the U.S. District Court, Eastern District, in St. Louis. That civil suit argues that sex offenders required to provide compelled speech violates the First Amendment to the U.S. Constitution because the First Amendment not only gives the right to speak but also a right not to speak at all. See Sanderson v. Bailey et a1.,4:23CY1242 JAR, (E.D. Mo. Jun. 14, 2024) (court denied motion to dismiss filed by the MissouriAttorney General and law enforcement defendants). As such, Mr. Moll's argument is intriguing because at the core of his claims, he argues that forcing people to register when their crime was committed before the laws were enacted, forces people to engage in forced speech, which is then published on the internet. Mr^ Moll also asserted the argument that in being required to registel when no such require- ment existed when he was convicted, violates the Thirteenth Amendment because it constitutes "invol- untaryservitude"to register. Mr. Moll cites cases Weidenfellerv. Kidulis,380 F.Supp,445,450 (E.D. Wis. 1974) (citing Stone v. Citv of Paucha, 120 KY 322,86 S.W.531, 533 (1905); and Doe v. Unocal Corp., 395 F.3d 932, 946 (9th Cir. 2002), to show Mr. Moll's argument is premised in law. On April 22,2A24, the Court denied Mr. Moll's pro se motion without giving a legal opinion and the Court ordered the case to proceed to trial, which was a bench trial and per the motion filed by the MissouriAttorney General, the bench trial was held in chambers and thus, without public knowledge in open court. The bench trial was held in secret, on April 24,2024. The Court found Mr. Mull guilty on all five individual Counts.
- 4. Although there is no indication in court records that Mr. Moll was impeded or prevented from registering because of any disability, Mr. Moll's case is intriguing nevertheless. Mr. Moll's case in and of itself brings to light issues that arise when a trial court summarily rejects constitutional claims of ex- tenuating circumstances and mitigating factors that have a legal basis in law, moreover, clearly estab- lished constitutional rights. ln the case of Doe, which Mr. Moll and his attorney argued, points out and holds: Here, however, the Does are not complaining that they have been held or will be held criminally liable for failing to register. They are complaining about application of the registration requirement to them, based solely on their pre-act criminal conduct. As to all but Jane Doe lll, who was not convicted until 1998, the application of that requirement truly is retrospective in its operation. lt looks solely at their past conduct and uses that conduct not merely as a basis for future decision-making by the state, in regard to things such as the issuance of a license, or as a bar to certain future conduct by the Does, such as voting. Rather, it specifically requires the Does to fulfill a new obligation and imposes a new duty to register and to maintain and update the registration regularly, based solely on their offenses prior to its enactment. This violates the standard set out in Bfss and violates our constitutional bar on laws retrospective in operation. See Doe 194 S.W.3d 833 at 852 Thus, it is a far-fetched claim for the State to accuse Mr. Moll of being some anti-government fanatic or terrorist because he asserts he is exempt from the laq when the Missouri Supreme Court it- self said the same thing in Doe, ld., and Mr. Moll's attorney also argued without the State claiming that she is anti-government. SENTENCING GUIDELINES & RECIDIVISM DATA ln the movie, Minority Report, which centers on preventing crimes before they occur, based on "precogs" predicting the future by using mental telepathy, John Anderton, played by Tom Cruse, stated that, "[i]f you don't kill me, precogs were wrong and precrime is over." Professor MichaelA. Wolf, former Chief Judge of the Missouri Supreme Court, wrote about the means, manners and purposes sentencing guidelines and recidivism data is used, to determine what, punishment to give someone who commits a crime. See 'Missouri Provides Cost of Sentences and Recidivism Data: What Does Cost have to do With justice?', St. Louis University School of Law, Legal Studies Research Paper Series, No. 2011-30. Professor Wolfs article effectively describes a system of government that relies on the "precog" argument of the government being able to predict that someone is guaranteed to commit a crime just by the government thinking it will happen. This concept presupposes that if a person commits a crime, statistics dictate the percentage risk that the person wilt re-offend. For example, as used in Professor Wolfs article, if a person com- mits an aggravating crime, there is a 39.6% risk the person will re-offend within two-years that a mini- mum prison sentence of five-years is recommended. But this approach ignores the 60.4% likelihood that the person will not re-offend, because the government prefers to use the "glass half full" approach to seemingly rationalize and justify locking someone up.
- 5. As Professor Wolf points out, in Missouri, there are three classifications of crime, in that of (1) typical, (2) mitigating and (3) aggravating. Each purports its own percentage risk of recidivism within a specified amount of time, and each makes recommendations in the sentence to impose. The Missouri Supreme Court points out registration requirements are premised on recidivism data and thus, based on [/lissouri's sentencing guidelines in criminal cases, Smith v. Sf. Louis Cnty., Police,.659 S.W3d 895, 899 (Mo. banc 2023), to classify sex offenders according to a tier level, e.9., Tier I (lowest or "typical"), Tier ll (moderate or "mitigating") and Tier lll (highest or "aggravating"). A lot of focus in the courts has centered on the question of whether sex offender registration and notification laws are "civil" or "punitive". See R. W. v. Sanders, 168 S.W.3d 65 (2005). First, the fact Smith at 899 admits registration requirements are premised on recidivism data in determining tier levels, according to Missouri's criminal sentencing guidelines and recidivism data, is a good indication that registration is punitive or have an intended punitive effect. Second, in, R W. a|69, the Court admits "registration statutes are located in Title XXXVlll dealing with "Crimes and Punishment[]"" and thus, giving further evidence that registration and notifi- cation laws are punitive or have an intended punitive effect. Third, in R. W at 69, the Court admits there is no concrete, absolute and particularized evi- dence showing that sex offender registration and notification laws are in fact intended for civil pur- poses rather than criminal punitive effects. Fourth, in R, W. at 69, the Court admits that it decided to just assume registration and notifica- tion laws are civil and not punitive even though it could not draw from the laws any actual declaration of Legislators that the laws have the purpose of being "civil" and not "punitive". Fifth, Mo. Rev. Stat. S 589.401.1 explicitly holds that "[a] person on the sexual offender registry may file a petition in the division of the circuit court in the county or city not within a county in which the offense requiring registration was committed" which shows the sex offender must obtain permission to be removed from the registry, by the crtminal courlthat sentenced individual. Sixth, S 589.401.8 explicitly holds "[t]he person seeking removal or exemption from the registry shall provide the prosecuting attorney in the circuit court in which the petition is filed with notice of the petition[]" which again shows registration and notification laws are in fact criminally punitive or have an intended criminal punitive effect, to establish and impose lifetime supervised probation. The Court has also pointed out the MO-SORA is required to substantially comply with federal SORNA laws: (1) SORNA, 34 U.S.C. S 20911(5), requires a conviction-based structure for sex offend- ers'registration and notification requirements and (2) SORNA,34 U.S.C. SS 20911(2)-(3), establishes three classes, or tiers, based on the nature and seriousness of the offender's sex offense. Thus, there is sufficient concrete, absolute and particularized evidence showing sex offender registration and notification laws constitute a criminal punitive effect, intent and purpose, in furtherance of the criminal sentence by imposed by the criminal court and requiring the lifetime supervised proba- tion, with ongoing reporting requirements. Finely, it cannot be left unsaid that while the Court alleged in Smith at 899 that registration and notification laws were enacted to protect children, the Court also admitted in Smr'fh at 90'1 that:
- 6. There are reasons the GeneralAssembly would want to keep the language of $ 589.400.1(7), and its interpretation, the same. SORNA requires every state "shall maintain a jurisdiction-wide sex offender registry conforming to the requirements of this subchapter." 34 U.S.C. $ 20912(a). Certain federal funds are linked to Missouri's substantial compliance with SORNA. "For any fiscal year after the end of the period for implementation, a jurisdiction that fails, as determined by the Attorney General, to substantially implement this subchapter shall not receive 10 percent of the funds that would otherwise be allocated for that fiscal year to the jurisdiction under subpart 1 of part E of title I of the Omnibus Crime Control and Safe Streets Act of 1968[.]" 34 U.S.C. S 20927(a) (citation omitted). So naturally, the Court wants to propagate that registration and notification laws are "civil" and not "punitive" because to be truthful, to stop being deaf, mute, and blind, means the Court would have to acknowledge the entire statutory scheme of registration and notification laws is unconstitutional. But given there is a financial vested interest in having the registry the Court is not about to admit the truth. SUPERVISED PROBATION REQUIREMENTS Once on the registry, and based on the person's Tier level, the individual is required to show up in-person to report to the local chief law enforcement office, much like reporting to the local probation and parole office. This is done every 9O-days, 18O-days or on an annual basis, again depending upon what Tier level the person is assigned. ln-person reporting is also required to occur within three busi- ness days when any change in preexisting registration information occurs. Reportable information includes, but is not necessarily limited to, the address where the person Iives, works, goes to school, vehicle information, what email addresses the person has, what social media sites the person uses, any new scars or tattoos the person has, any new alias names used, and any place the person volunteers or serves as an intern. The person is required to have a photograph (mugshot) taken at least annually, which is then published on the internet for the public to better identify the person out and about, and to have his or her fingerprints taken. ln Sheriff Arnott's policies, which are discussed later in this report, and in Sanderson v. Bailey et al., No. 4:2023cv01242 (U.S. Dis. Ct. E.D. 2023), sex offenders are also required to submit to state compelled speech by specific words, types, methods, means, and forums of speech, or be criminally charged for the failure or refusal to comply. These registration and notification laws impose concrete, particularized and absolute chilling effects on political speech, religion, individual liberties and rights; housing and employment opportuni- ties; state professional licenses; free speech, privacy, therapeutic treatment, care, support, mainte- nance and habilitation, and the personal and/or physical safety of the sex offender. These registration laws and resulting supervised probation apply whether the crime involves a minor child or an adult; whether the person committed one crime or one hundred; regardless whether the person remains crime free for one day or one hundred years; whether the person is 1S-years-old or 500-years old, because the laws presuppose and label every sex offender as repeat offenders and erron.eously hold every sex offender out to be a pedophile, a predator, a deviant monster, etc., and endanger the lives, health, safety and welfare, real and personal property of not only the sex offender but everyone living with the person.
- 7. Thus, whrle argumentatively sex offender registration and notification laws may have been cre- ated in 1996, in tIissouri, to protect children and having a civil purpose, in reality, these laws are used and enforced as weapons to impose far-reaching punitive effects. MANDATORY LI FETIME REGISTRATION ln 1994, Congress enacted the Sex Offender Registration and NotificationAct (SORNA) and in '1996, Missouri enacted its Sex Offender Registration Act (MO-SORA). Thus, SORNA is a federal law whereas MO-SORA is state law. Missouri was required to enact MO-SORA to comply with federal laws in SORNA, tf Missouriwants federalfunding from the Omnibus Crime Control and Safe Streets Act of 1968. Smith 659 S.W3d 895 at 901. The Omnibus Crime Control and Safe StreetsAct of 1968 provides block grants, discretionary grants, crim ina I j ustice facility construction, and the training of State and local criminaljustice personnel by the Federal Bureau of lnvestigation. Therefore, while the Missouri Supreme Court, Legislators and law enforcement personnel like to claim MO-SORA is to "protect children", the fact remains, it is financially motivated and financially benefited from, and both the federal grip and the strength of its grip on Missouri having its SORA has everything to do with money. ln reality, Missouri could very well chose to forego the 10% federal funding, eliminate SORA in totality, and put an end to the far-reaching devastation that the registry causes everyone. But that will not happen and in 2023, the Missouri Supreme Court made sure that it does not happen. h 2A23, two individuals appealed the circuit court's order denying their petitions to be taken off the Missouri sex offender registry. Both argued that Mo. Rev. Stat. S 589.400 et al, and $ 589.40'1 et al do not impose lifetime registration requirements. The Missouri Supreme Court heard both appeals with the Court affirming the circuit court's rul- ings against both Smith and Ford. "The circuit court concluded MO-SORA, specifically $ 589.400.1(7), requires lifetime registration for anyone who has ever had to register in Missouri for an offense that re- quired registration under SORNA.' See Smt'ffi at 898. ln 2018, the Missouri GeneralAssembly created a three tier classification of sex offenders sup- posedly to give sex offenders the opportunity to be removed from the State's sex offender registry. The Missouri Supreme Court pointed out that "[w]hile the GeneralAssembly added language to, and removed language from [$ 589.400.1] subdivision (7) in the 2018 amendments to MO-SORA, the language imposing a registration requirement for "[a]ny person who is a resident of this state who ... has been or is required to register under tribal, federal, or military law" remained unchanged. Smith at 900. The Court also noted that, "[t]he GeneralAssembly was aware of this Court's interpretation of $ 589.400.1(7) al the time of the 2018 amendments and chose to leave the language regarding federal registration unchanged ." Smith at 90'1. Thus, the Court blames Legislators but, in reality, the Court will just find some other pretext excuse to ensure lifetime registry occurs even if Legislators were to make additional changes to $ 589.400.1(7) to ensure removal from the registry occurs.
- 8. ln 2006, the Missouri Supreme Court ruled that retroactively applying sex offender registration laws to require sex offenders to register is unconstitutional. See Doe v. Phillips,194 S.W.3d 833 (Mo. 2006). As a result, roughly 3,800 sex offenders were exempt from having to register, with Doe being the controlling case law. ln 2023, the Missouri Supreme Court asserted that "[t]he registration requirement pursuant to $ 589.400.1(7) continues even afterthe individual's federal registration obligation pursuant to SORNA has expired because "the state registration requirement is based on the person's present status as a sex offender who 'has been' required to register pursuant to SORNA ." Smith at 901 . Therefore, the Court ultimately concluded, "[t]he circuit court did not err in concluding Smith and Ford were not entitled to removal from the Missouri sex offender registry because S 589.400.1(7) mandates registration fora person's lifetime if they "ha[ve] been ... required to register under... federal ... law[.]" The circuit court's decisions are affirmed." Smith at 904. ln the dissenting opinion of Missouri Supreme Court Judge Patricia Breckenridge, she asserts that, "[i]n affirming the circuit court's judgments denying Mr. Smith's and Mr. Ford's petitions to be removed from Missouri's sex offender registry, the principal opinion reads subdivision (7) of section 589.400.1 out of context and misstates this Court's holding in Doe v. Toelke 389 S.W.3d 165, 167 (Mo. banc2012). See Smiffi at 904. Judge Breckenridge premised her dissent on two primary arguments: ln the first instance, the principal opinion ignores the first seven words in section 589.400.1 that precede the eight subdivisions that follow When properly read, the plain language of section 589.400.1(7) does not mandate lifetime registration for every person who has been or is required to register under federal law. The relevant portion of section 589.400.1(7) states, " Sections 589.400 to 589.425 shall apply to: ... (7) Any person who is a resident of the state who ... has been or is required to register under ... federal law[.]" Subdivision (7) provides merely that residents of Missouri who have ever been required to register by federal law are subject to MO-SORA's provisions." ld. The principal opinion's mischaracterization of the Court's holding in Toelke is the foundation for its flnding the GeneralAssembly's failure to amend section 589.400.1(7), when it amended other provisions of MO-SORA in 2018, shows its intent to continue mandatory lifetime registration for persons who have ever been required to register under federal law. The principal opinion then employs that mischaracterization to justify not applying the registration requirements in section 589.400.3-.4, enacted in 2A18- ld., af 905 ln terms of the devastating reach of the Court's ruling, the Missouri GeneralAssembly decided to amend S 589.400 for at least a selected group of sex offenders to have reprieve from the registry in being permitted to petition the circuit court for removal off the registry. But, as Judge Breckenridge points out in her dissent, "[n]early every person convicted of a sexual offense in Missouri is required to register pursuant to SORNA, and, under the principal opinion's interpretation, section 589.400.1(7) requires all such persons to register for their lifetimes, regardless of any other provision in sections 589.400 to 589.425;' Smith af 908-9
- 9. SEX CRIMES BY PEOPLE WITH DISABILITIES Among individuals labeled sex offenders, there is a uniquely situated class of people because of their qualifying disabilities. I would be remiss if I did not include them in this report, especially since I am a court appointed legal guardian of an adult labeled a sex offender. Thus, to start it is important for me to address the scope of the issues and then discuss the reasons the issues exist. ln an undated report published by The Arc,'People with lntellectual Disabilities and Sexual Ol- fenses', which was written by Leigh Ann Davis, M.S.S.W, M.P.A, TheArc reports that: One comprehensive review of sex offenders found that approximately 10% to 15o/o of all sexual offenses are committed by people with intellectual disabilities, which is only slightly higher than the general population (around 9%) (Murphy et al., 1983). Another study found that almost 50o/o of incarcerated offenders with intellectual disabilities and 34o/o of those living in the community had been convicted of sex offenses (Gross, 1985). The most frequent sexual offenses reported in one study were indecent exposure, other minor offenses, and sexual assault of young girls (Day, 1997). Another nationwide study that surveyed243 community agencies found the most common sexual offenses were inappropriate sexual behavior in public (62.20/o), sexual behaviors and stimulation that inappropriately involved others (42.60/o), sexual activity involving minors {42.60/o) and assaultive/nonconsensual sexual activity not involving minors (34.5o/o) (Ward et al, 2001). Another study found the most common sexual behaviors are those seen among people without intellectual disabilities - offenses against children, genital exposure and rape (Murphy, et al., 1983) The Arc report also points out that factors explaining why this class of people engage in what is a sex crime, which include: Lack of information about or opportunities for sexual expression and intimacy; Lack of social skills and training on appropriatelsafe sexual behavior and building relationships resulting in a significant lack of sexual knowledge; victimization among people with developmental disabilities compared to those without disabilities); and See https:i/www.thearc.org/wp-contenVuploads/forchapters lSexualo/o20Offenses.pdf Notwithstanding the aforesaid, in my article, 'False Confessions: Protecting the Vulnerable'that is published in The Crime Report (April27, 2022) I discuss the issue of individuals with disabilities be- ing found guilty of serious crimes such as sex crimes, as a result of giving false confessions of guilt. https://thecrimereport. org?AZ2l04l27lhow-states-fail-to-protect-vulnerable-suspects-from-false-con- fessions/
- 10. ln my article I cite the article, 'Mental lllness and False Confessions: A Wakeup Call to lnvesti- gators', (Crime Report, December 15,2021) by Joseph P. Buckley, who provides a detailed analysis of why people with disabilities give false confessions of criminal guilt. https://thecrimereport. orgl2021l12115lmental-illness-and-false-confessions-a-wakeup-call-to-investiga- tors/ Regardless why a person with disabilities is on the sex offender registry, their disabilities make them exceptionally vulnerable to abuses of power, abuses of process, violations of due process rights and liberties, and being forced to live with a bullseye on their forehead for civil commitment targeting. ADMINISTRATIVE PROCESSING FEES Pursuant to Mo. Rev. Stat. $ 589.400, sex offenders may be charged a civil administrative pro- cessing fee to register for the first time and thereafter, to update or change their preexisting registra- tion information, as the state law provisions hold: 6, For processing an initial sex offender registration the chief law enforcement officer of the county or city not within a county may charge the offender registering a fee of up to ten dollars. 7 . For processing any change in registration required pursuant to section 589.414 the chief law enforcement official of the county or city not within a county may charge the person changing their registration a fee of five dollars for each change made after the initial registration. The provisions above and the legislative language used clearly demonstrate not only that the administrative processing fee is civil and discretionary but also, in being discretionary, the fees are not mandatory as a matter of law and thus, the fees can in fact be waived. What is noticeably absent in the above two provisions of the state law is that the chief law en- forcement officer of the county or city not within a county does nof have any statutory authority to use internal sex offender registration policies to impede or prevent sex offenders from registering. For example, an internal policy preventing a sex offender from registering until such time as he or she performs a concrete, absolute and particularized act, is unauthorized in both provisions above, as they do nol give the local law enforcement official anv legal authority to implement such policies. ln exercising its legislative powers and authority, the Missouri General Assembly decided that the fees should be discretionary and not mandatory because making them mandatory would consti- tute their being a fine or penalty. Moreovel if the fees were mandatory, as law, it would put individuals who cannot financially afford them at risk of being criminally charged for a lack of financial resources. It would create a perpetual debtors' prison to mandate the fees be paid, as law, that is contrary to ensuring those required to register have every open and viable opportunity to do so. Thus, Legisla- tors left it discretionary in whether administrative processing fees are charged. lf the fees are charged but a person fails or refuses to pay them, then the remedy is for the law enforcement entity to either waive the fees or pursue civil remedies in an Associate Circuit Court on a small claims civil suit filed.
- 11. All that said, where an internal policy imposes a new obligation, duty or disability that does nof exist in law, then the policy itself is a nullity, void ab initia and ultra vires because the policy does not have the force and effect of law A policy that prevents a person registering anless he or she pays the administrative processing monetary fee and thus, creates a criminal penalty for failing to register, is a policy withoutthe force and effect of law. Rather, it is a financial racketeering scheme instead. RECIDIVISM RATES AMONG SEX OFFENDERS On December 10, 2A13, I participated in a panel discussion that included former Chief Justice Wolf of the Missouri Supreme Court and state officials. The discussion was conducted and published by Missouri Digital News. trdissouri Digital News reported, "liln 2A12, a Missouri Supreme Court judge said that of the five categories of felony offenders in Missouri's correctional population, sex offenders have the lowest rates of recidivism." https://www md n. orgl20 1 3/STO Rl ES/SO RTS. HTM This was discussed in Sfate v. Peterson, SC92491, in which the Respondent's brief points out that: While the State has a legitimate in protecting the public, this cannot come at the cost of individual constitutional rights. The number of statutes seeking to regulate and restrict sex offenders is ever-increasing. This perceived need for increased protection from those convicted of sex offenses is based on perceptions that sexual ofienders have startling rates of re-offending. This Court has recognized that this perception simply isn't supported by empirical data: While recognizing the dissent's evident concern about recidivism of sex offenders, rather than assuming that the rates are high, one should look at the data. Of the five categories of felony offenders in Missouri's conectional population -- drugs, nonviolent felonies, violent felonies, DWI (driving while intoxicated) felonies, and sex and child abuse -- sex offenders have the lowest rates of recidivism. Their rate of recidivism after two years is 5.3 percent, while recidivism rates for other categories of offenders are 9.6 percent for violent offenders, 14.9 percent for nonviolent offenders, 11.7 percent for drug offenders, and 11 .4 percent for felony DWI offenders. The rate of recidivism includes the likelihood of a convicted sex offender to commit any future crime, not just a sex offense. Missouri Sentencing Advisory Commission, Recommended Sentencing Biennial Report 2009 at http://wrrrnv. mosac. mo. gov/fi le/2009%20Bien n ia l%20Re port. pdf https:/lmitchellhamline.edu/sex-offense-litigation-policylwp-contenUuploads/sites 16112018108/Respon- dents-Brief.pdf The recidivism data above was also cited in the defendants' brief in Toelke v. Doe, SC92380. https://wrlrw.courts.mo.gov/SUP/index.nsf/O/ff74b0bd2da95b4486257a5a006e72d9/$FILE/SC92380- John_Doe_brief.pdf
- 12. As the recidivism data above shows, while there are certainly incidents of individuals engaging in further criminat conduct, the greater takeaway is that in spite of information propagated by media, Legislators, and others to seemingly rationalize and justify overbearing laws to micromanage people on the sex offender registry the overwhelming vast majority of sex offenders to not re-offend. According to the Thmpa Bay Times, December 16, 2021, published article, 'Sex offender reg- istry laws don't work. Here's what mighti a plethora of empirical evidence in numerous credible stud- ies based on decades of researched data shows there is no significant evidence supporting the effec- tiveness of sex offender registries in protecting public safety and preventing sex crimes. Some studies go so far as to point out that sex offender registries create factors that perpetuate criminal activity. https:/lwww.tampabay.com/opinionl2021l12l16lsex-offender-registry-laws-dont- work-heres-what-m ig ht-co Ium n/ Sex offender registry laws are invariably predicated on fear, hate, high profile cases, the lack of understanding about sex crime factors, propaganda from law enforcement, legislators, and the media, and personal beliefs, thoughts and experiences people have, in being previously victimized or knowing someone who has. And the rnore vile sex offenders are portrayed the more people feel, without having evidence, that sex offender registries are needed. While it may seem contradicting that on one hand Tampa Bay Times reports the difficulties that sex offenders encounter because of the barriers sex offender registration and notification laws create, but on the other hand, recidivism data in Missouri shows a very low percentage of recidivism occurs, to suggest what Tampa Bay Times reports is false, it is not. The statutory scheme of sex offender registry laws, moreover, publicizing thelr biography and their mugshot, intentionally puts a bullseye on every individual with purpose to make them public en- emy number one. lt is patently absurd to think this does not impose far-reaching tangible adverse and pervasively detrimental effects on these individuals. And for people with disabilities who are sex offenders, these laws and the internal policies used such that Sheriff Arnott has implemented, exploit the vulnerabilities they have tofurther punish a sex offender. They create platforms for laws to be violated that would not otherwise occur but for policies such as SheriffArnott implemented. Thus, when contemplating sex offender registration laws in and of themselves, and factoring in internal policies such that Sheriff Arnott implemented, which pervert the law, are an abuse of process and forcibly create barriers for sex offenders with disabilities to comply with registration laws, the laws and policies are grossly inadequate and further criminalize disabilities. FINANCIAL BARRIERS Historically, people with disabilities are regulated out ol being gainfully employed whether it is because of their disabilities or because of disabitity-based discrimination in employment opportunities. As a result, people with disabilities frequently endure substantial limitations in their financial resources. For example, and using my own ward of guardianship as the example, because of his disabili- ties that render him incapable of being gainfully employed, he receives a monthly amount of nine hun- dred fortythree dollars ($9+S1 in Supplemental Security lncome. He also receives the maximum sum allowed for a single male in SNAP benefits of two hundred twelve dollars ($212.00). His essential cost of living amount is eight hundred fifty dollars ($850.00) per month. The remaining ninetythree dollars ($93.00) is spent on food (to supplement his SNAP benefits), and on domestic and hygiene needs.
- 13. h 2A23, the U.S. Bureau of Labor Statistics reported that the employment-population ratio for people with disabilities ages 16 to 64 in the United States was 37.1%. ln Missouri, the 2023 employ- ment-population ratio for people with disabilities was only 22.5o/o. ln 2022, the federal Social Security Administration reported that six thousand three hundred sixty-three (6,363) people living in Greene County, Missouri received some kind of social security ben- efits. The Social Security Administration reports that among them, two thousand one hundred seven- teen (2,117) received Supplemental Security lncome. No known studies exist, to extrapolate data that shows the number of people in Greene County receiving social security, being sex offenders. ln2020, Ozarksfirst.com reported that Greene County ranks 6th in Missouri in the total number of sex offenders, with nine hundred twenty-five (925) existing, whereas City-Data.com reports that as of July 20,2024, eight hundred fifty-three (853) people living in Springfield, Missouri are sex offenders. ln 2020, for example, the City of Springfield, Missouri reported the financial poverty rate by Zip Code to be: 65802 (25.7o/o,65803 (23.8o/o),658M (12-8o/o),65806 (51.0%),65807 (22.4o/o),65809 (6.0%) and 65810 (6.7%). Therefore, it is more likely than not adult sex offenders suffer high rates of economic poverty, especially among those living in the 65806 Zip Code residential neighborhoods. TITLE IIADA VIOLATIONS On April 8,2024, the U.S. Department of Justice implemented its final rule that establishes the 'Web Content Accessibility Guidelines (WCAG) 2.1 Standard, Level AA, by the creating subpart H to Title ll of the Americans with Disabilities Act, in 28 C.F.R. Part 35. The purpose of doing this, is to force both State and local governments to comply with Title ll of the Americans with Disabilities Act, by ensuring their individual websites are accessible to people with disabilities because the State and local governments consistently violate Title ll. As governments utilize websites and portals to purportedly provide goods and services, and for people to participate in government programs and activities, when State and local governments do not comply with Title ll requirements, it imposes tangible adverse effects on people with disabilities. This is especially important when, policies foreclose all other avenues for individuals to participate in activities and programs the government is statutorily required to provide. When individuals face the prospect of being criminally prosecuted and imprisoned, especially for 150-vears as Mr. Moll's case shows, for not complying with laws that require their participation in a government program, service or activity, then government policies that impede or prevent their being able to participate, pervert the law and constitute an abuse of process. SHERIFF ARNOTT'S POLICIES Sheriff Jim Amott of the Greene County, Missouri Sheriff Department, implemented two internal policies on sex offender registration requirements. Policy #1 prevents sex offenders from registering for the first time and from providing updates or changes to preexisting registered personal information, if the sex offender does not pay the full sum of a private civil administrative processing fee allowed in Mo. Rev. Stat. S 589.400.6 and 7 (2018) and thus, attaches a criminal penalty for failing to pay.
- 14. Policy #2 prevents sex offenders from scheduling appointments to register for the first time or from updating or changing preexisting registered personal information, unless the sex offender has an email address and unless the sex offender uses the Greene County Sheriff Department website portal and thus, attaches a criminal penalty for failing to perform forced speech. Here is the problem:The aforesaid policies are notauthorized anvwherein Arystate law (Mo. Rev. Stat. S 589.400 to $ 589.426). ln fact, absolutely nowhere in $ 589.400.6 and 7 is Sheriff Arnott given E2ystatutory authority to implement policies lhat impede or preventsex offenders registering. Moreover, absolutely nowhere in Mo. Rev. Stat. S 589.400 to $ 589.426 is Sheriff Arnott given a1y statutory authority to require or force sex offenders to use the internet, specific websites or have an email address to communicate and participate in the state sex offender registration program. The U.S. District Court recently denied the joint motion filed by the MissouriAttorney General and local law enforcement, to dismiss. See Sanderson v, Bailey et a1.,4:23CV1242 JAR, (E.D. Mo. Jun. 14, 2024)). The case involves the alleged right of the State and local law enforcement to force sex offenders to engage in specific forms of speech. The civil suit argues that the requirement to post a sign on Halloween night violates constitutional rights guaranteed under the First Amendment. Thus far, the U.S. District Court has agreed with the plaintiff, who is a sex offender, Similarly, Sheriff Arnott has implemented two policies that force sex offenders to engage in the concrete, absolute, and particularized speech that he demands. First, as the U.S. Supreme Court pointed out in the infamous case of Citizens United v. Fed- eral Election Comm'n, 558 U.S. 310 (2010), money is a form of speech that falls under the purview of First Amendment rights, liberties, privileges and protections. Creating a policy that prevenfs a person from registering if the person does not pay money for civil administration processing charges allowed by S 589.a00.6 and 7, is itself compelled government speech. And attaching a criminal penalty to the policy whereby the person is criminally charged and prosecuted, then imprisoned, for failing to register because of the policy that prevents them from doing so, is compelled government speech and constitutes an illegal and/or unlawful financial racketeering scheme inflicted against people because of their vulnerabilities - very much like a mafia tactic. Second, in Sanderson 4.23CY1242 JAR (E.D. Mo. October 27, 2023), the federal court points out that "First Amendment protection "includes both the right to speak freely and the right to refrain from speaking at all." When a policy prevents a person registering by mandating the person is to communicate only in one way, to schedule an appointment to registel and the policy eliminates any and all other viable ways to communicate, including ways that reasonably accommodate people because of disabilities, it is compelled government speech. Moreover, when that policy also mandates a person is to have an email address to schedule an appointment to register, it is compelled government speech. And when the policy attaches a criminal penalty of failing to register because a person could not or did not speak as the policy dictates, it is also compelled government speech. While there is absolutely nothing wrong having an alternative way to schedule appointments by an on-line govemment portal, the policy cannot foreclose any and all other ways to communicate. This is specifically, expressly and substantially important for people with disabilities and people subject to a court order not to use the internet or not to have or use email to communicate. These individuals are likely the most vulnerable to being criminally charged for failing to register because their barriers; the absence of other viable way to communicate and the policy preventthem from registering.
- 15. lf there is anything abundantly clear about the MO-SORA it is that the State wants people to be registered. Therefore, it is counterproductive to create policies that prevent people registering and it is unconscionable to criminally punish a person for failing to register when the internal policies prevent people from registering. Sheriff Arnott's policies not only constitute an abuse of power, abuse of process, violations of a wide array of state and federal laws, but they also literally entrap people in criminal conduct that would not otherwise exist but for his illegal and/or unlawful policies. REFUSAL TO COMPLY WITH COURT ORDER On October 27,2023, the U.S. District Court, Eastern District, for Missouri issued its order that prohibits enforcement of the provision of state law, requiring sex offenders to post a sign on Halloween night, stating "no candy or treats at this residence". Sanderson v. Bailey et al., No. 4:2023cv01242 (U.S. Dis. Ct. E.D. 2023). See also Mo. Rev. Stat. $ 589.426.1(3). On July 23,2024, and in response to my prior emailed inquiry on whether Sheriff Arnott plans to comply with this Court order, I received the emailed response below from the Greene County Sherlff Department paralegal for and on behalf of Sheriff Amott: We have asked Damon Phillips, Greene County Sheriff's Office legal counsel, for an update on this matter. Per Mr. Phillips, the temporary restraining order is still in place but it only applies to the named defendants, not any other law enforcement officer or agency. The merits of the restraining order are going to be resolved with the trial. The bench trialwas held on June 20, 2A24. The parties are now in the process of submitting briefs and yesterday, the court granted leave to file an extended brief. ln short, nothing has changed since last year. It is our understanding that the Halloween signs will still be required, ln my reply email, dated July 23, 2024,1 wrote: Thank you for your reply. Please inform the GCSD I Damon Phillips] he/she might want to re-read the court's order dated October 27,2423 The Court explicitly wrote: Further, because the Court has found a likelihood of success on the merits that Missouri revised Statute Section 589.426.1(3) is unconstitutional, this Order applies to any person affected. not iust Plaintiff, and such relief will not impose any additional burden on Defendants. (Emphasis added). As such the TRO in place is state wide, prohibiting any and all sex offenders from having to post the sign on Halloween night. lf the GCSD and Arnott proceed in requiring the sign be posted then they are blatantly, willfully and wantonly and maliciously violating a direct court order. The suit was filed against both the MissouriAttorney General and the local law enforcement of- ficials located in City of Hazelwood, Missouri. The suit challenges the constitutionality of state law that requires sex offenders to post a state mandated sign on Halloween night pursuant to state law, Mo. Rev. Stat. S 589.426.1(3), stating "No candy or treats at this residence".
- 16. ln filing the suit against the MissouriAttorney General, the plaintiff seeks statewide remedies to prohibit enforcement of the state law. See Complaint at fl 36 (pointing out that it is not just the plaintiff who is adversely affected by the provision of this state law). While the suit has not yet concluded, as the above email points out, the Temporary Restraining Order remains in full force and effect. The parties in the action are still in the pleading stage and thus, it is unknown at this time when finality of the case will occur. The Sanderson suit challenges the constitutionality of the state law being enforced. The Court determined a likelihood of success of the suit exists, based on the merits of the claim. Thus, the Court issued a Temporary Restraining Order that forbids the state law being enforced. The Court explicitly pointed out that its order is not exclusive to the parties in the action but instead tt applies to any per- son affected. This means the Temporary Restraining Order is sfaferaride, and prohibits requiring any and all sex offenders throughout Missouri, from having to post the sign on Halloween night. Sheriff Arnott's aforesaid emailed response clearly asserts that he does not intend to comply with the Court's order and instead, do whatever he wants to do. CIVIL COMMITTMENT OF SEX OFFENDERS WITH DISABILITIES Throughout the December 10, 2013, Missouri Digital News segment on sex offenders having a disability, discussions centered on civilly committing these sex offenders for the rest of their lives. I pointed out, in that discussion panel, that "[t]hey've served their time, they maxed out on their prison sentence. So to keep them in civil commitment without giving them treatment is absolutely puni- tive." https : i/www. md n. org/20 1 3/STO Rl ES/SO RTS. HTM The argument of the State and courts is that civil commitment is a humane process by which a person receives treatment so they do not commit further sex crimes because of their disabilities. This argument is very similar to the one Missouri used in the 1800s to warehouse people in St. Joseph, Missouri at the "State Lunatic Asylum No. 2" for the rest of their lives. Civil commitment just like using jails and prison to warehouse people with disabilities became the chosen response to the 1999 U.S. Supreme Court ruling in Olmstead v. L.C.527 U.S. 581 (1999) which required states to release people with disabilities from state institutions. By states labeling these people as mentally defective that they are more likely than not to commit crimes because of a mental or abnormality in the brain, courts were willing to act deaf, mute, blind to the crimes against humanity. Professor MichaelA. Wolf stated, "[b]ut if they're not there for treatment and there's no possibil- ity they'll get out, then l'm not sure that the rationale for civil commitment is really met[]" to also point out civilly committing sex offenders with disabilities has become a death sentence rather than avenues for treatment that leads to reintegration back into society. Hal Lowenstein who was an attorney with Armstrong Teasdale in Kansas City, and appointed by the U.S. District Court, Eastern District, to represent plaintiffs in a civil suit filed against the Missouri Department of Mental Health, involving civil commitment, pointed out that, "[t]he fact that nobody has crossed the finish line out of all these people who've been involved really kind of tells the tale that once you're there, you're there."
- 17. And Former Lieutenant Governor Kenneth Rothman is quoted in saying, "[w]e have to have a balance. Yeah, we owe these people some help if we can give it to them, but we really owe the people who would be innocent victims if they were released[]" to assert that civilly committing sex offenders for life is somehow justified and rationale based on only a "purely speculative theory of recidivism" The point is that what makes Sheriff Arontt's two policies so ertremely dangerous for sex of- fenders with disabilities is that these policies pave the way to fast track people with disabilities to civil commitment for the rest of their lives. Mo. Rev. Stat. $ 632.484.1 QAM) holds, in relevant part: When the attorney general receives written notice from any law enforcement agency that a person, who has pled guilty to or been convicted of a sexually violent offense and who is not presently in the physical custody of an agency with jurisdiction has committed a recent overt act, the attorney general may file a petition for detention and evaluation with the probate division of the court in which the person was convicted, or committed pursuant to chapter 552, alleging the respondent may meet the definition of a sexually violent predator and should be detained for evaluation for a period of up to nine days. The statutory terms "recent overt act" is defined in $ 632.480.5, which holds For the purposes of this section "recent overt act" means any act that creates a reasonable apprehension of harm of a sexually violent nature. Thus, a sex offender with disabilities who fails to register because of either or both of Sheriff Arnott's policies, falls within the purview of $ 632.480.1 because failing to register would constitute be- ing a "recent overt acf' that can easily be said to be or manipulated to be " reasonable apprehension of harm of a sexually violent nature". The term recent overt act does not mean a sexually violent act must occur. Rather, it is good enough to simply, merely and only claim reasonable apprehension exists that some day in the future, the person might engage conduct that inflicts harm of a sexually violent nature because the person failed to register. ln the movie, Minority Report, which centers on preventing crimes before they occur, based on "precogs" predicting the future by using mental telepathy, John Anderton, played by Tom Cruse, stated that, "[i]f you don't kill me, precogs were wrong and precrime is over." Thus, S 632.480.5 is predicated on this premise, whereby the State claims that the shoot first scenario is the best approach so the State can say it is right, because if the person is not civilly com- mitted and does not inflict "harm of a sexually violent nature", then it proves the precogs (State) are in fact wrong. Even if the allegation is completely false, the individualwould still be incarcerated, theoretically, for nine days by statute, to be evaluated. Howevel the St. Louis Public Radio points out in its article, on September 20, 2023, that people in county or city jails, wait an average of eight months, to receive court-ordered mental health services. https://www.stlpr.org/government-politics-issues/2023-09-2Olmissourians-wait-an-average-of-8-month- s-i n-jail-for-cou rt-ordered-mental-health-services
- 18. EFFECTIVENESS OF SEX OFFENDER REGISTRY LAWS Professor Meghan M. Mitchell, Professor Kristen M. Zgoba and Dr. Alex R. Piquero, who jointly authored the article in the Tampa Bay Times, point out that: We need to educate the public, law enforcement and policy makers that governmental oversight of registrants is not a feasible solution to protecting potential sexual abuse victims. [Evenso...] ln the end, parents, community members, and potential home buyers and renters will continue to frequent the sex offender registration website, gathering a false sense of safety - potentially at their own peril- untilwe . . . are willing to . , . accept the fact that sex offender registration and notification policies demonstrate little value in making a meaningful impact. Tough-on-crime policies are not always smart policies. lt is time to do better. Sex offender registration and notification laws result from political agendas, high profile cases, assumptions, hearsay, bias or prejudice, hate, and fear, allwhile grossly lacking empirical data to sup- port their use and the indifference to the tangible adverse effects they create and impose on everyone. Sex offender registration and notification laws create a false sense of security and promote the belief that responsibility for personal safety is not an individual's obligation but the duty of the State to provide for them, without empirical evidence that proves these laws actually protect public safety. The sex offender registry tier classification system completely ignores mitigating factors such as, but not limited to, aging out of crime, mile-markers that sex offenders achieve, individual recidivism risks and the lack thereof, and prosocial structures. lt erroneously presupposes that the sex offender is not and cannot be any more than criminal sentencing guidelines classify their crime to be. Unfortunately, with the State, law enforcement and the courts having a financial vested interest in having the MO-SORA, they resist, if not zealously fight against, reforms to the sex offender registry laws, that mean letting people off the registry. CONCLUSION When we use sex offender registration and notification laws as a weapon to impose a lifetime criminal supervised probation that impedes or prevents prosocial living, we have serious problems in the way sex ofiender registration and notification laws operate and are being enforced. When a sex offender labels someone as an anti-govemment fanatic or terrorist for asserting a constitutional claim against a registration law being retroactively applied, we have serious problems in the way sex offender registration and notification laws operate and are being enforced. When a sex offender can be sentenced to prison for 1S0-years for failing to register, we have a very serious problem in the way sex offender registration and notification laws operate and are being enforced.
- 19. When a sex offender is impeded or prevented from registering because of policies that demand they pay money to avoid criminal prosecution, and communicate only in one way, we have a very seri- ous problem in the way sex offender registration and notification laws operate and are being enforced. When criminal penalties attach to the offense of failing to register, do not take into account a sex offende/s disabilities that create mitigating factors, we have a very serious problem in the way sex offender registration and notification laws operate and are being enforced. And When law enforcement officials believe they are entitled to interpret or apply the laws however they want, to implement policies that impede or prevent sex offenders registering, we have extremely serious issues in the way sex offender registration and notification laws operate and are enforced. When law enforcement officials believe they are entitled to violate court orders forbidding the enforcement of a sex offender law or provision, then we have extremely serious issues in the way sex offender registration and notification laws operate and are enforced. But When the halls of justice are deaf, mute, and blind to what is going on, to the means, manners and Draconian ways that sex offender laws are being interpreted and applied, then we have more than just serious issues in the ways that sex offender registration and notification laws operate and are en- forced. We have a shutdown in the rule of law that is perpetrated by those who hold themselves out to be fair and impartial - all while having a financial interest at stake to ensure that no one ever obtains their freedom from the Missouri Sex Offender Registration Act. Christopher C President Duly court appointed legal guardian Secretary of State Participant #430039 P.O. Box 1409 Jefferson City, Missouri 65102 Emai I : Legal_GuardianT7 @yahoo. com This report, in whole and in every part is for informational and educational purposes only and is not, does not and should not be construed to be legal advice.