Alaska Supreme Court

State of Alaska, Department of Public Safety, Appellant v. John Doe I, Appellee. John Doe Ii, Appellant, v. State…

August 10, 2018425 P.3d 115

Summary

The court held that Alaska's sex-offender registration statute requires a categorical comparison of the elements of an out-of-state offense and the relevant Alaska offense, rather than an inquiry into the underlying conduct. Applying that standard, neither the Washington nor California statutes was similar enough to the Alaska offense of attempted sexual abuse of a minor, so neither Doe was required to register in Alaska. Justice Stowers, concurring, agreed that the categorical approach followed the statute's text, while Justices Fabe and Matthews concurred in the result but questioned whether the court needed to resolve the proper comparison method.