Alaska Supreme Court

Byron E. Charles, Petitioner v. State of Alaska, Respondent

April 25, 20142014 Alas. LEXIS 71

Summary

The court adopted a bright-line rule requiring new constitutional rules to apply to criminal cases pending on direct review or not yet final, replacing the prior balancing approach for such cases. Because the constitutional ruling invalidating application of the sex-offender-registration statute to persons whose underlying offenses predated the statute was issued while Charles's case remained on direct review, it applied to him. Although Charles had not previously raised the issue, allowing his conviction under a statute that could not constitutionally apply to him would perpetuate manifest injustice, so the court reversed the conviction.