Arizona Supreme Court
State of Arizona v. Lynn Lavern Burbey
October 13, 2017
Summary
The court held that a registered sex offender who moves from a residence to homelessness is subject only to the statutory requirement to register as a transient every ninety days, not the seventy-two-hour requirement to report a new residence or address. The court found the statute ambiguous, construed it as a whole and in light of its purpose, and adopted the interpretation that avoids constitutional vagueness concerns. It vacated the court of appeals’ opinion and reversed Burbey’s conviction and sentence.