Juveniles and Sex Offender Registration

In the case of the State of Florida versus Melissa Hope Williams, Ms. Williams moved to Florida in 2005 from Michigan where she had been adjudicated delinquent for a misdemeanor sex offense and required to register as a sex offender. She was 11 years old when she committed her crime and 13 years old when she was adjudicated delinquent by a Michigan court for committing that crime. When Williams moved to Florida in 2005, she registered as a sex offender with the Florida Department of Motor Vehicles, but she failed to re-register when she changed her address in 2009. Because of that, she was charged in criminal court with failing to register as a sex offender.

Williams asked the judge to dismiss the case against her because according to Florida law, a person is a sexual offender when that person "as of July 1, 2007, has been adjudicated delinquent for committing, attempting, soliciting or conspiring to commit certain [sex crimes] in [Florida] or another jurisdiction when the juvenile was 14 years of age or older." The judge dismissed her case, so the prosecutor appealed.

The court of appeals agreed that Williams' case should be dismissed because she was only 13 years old when she was adjudicated delinquent in Michigan.