Supreme Court of Missouri
Liana MacColl (formerly known as Liana M. Bradford) v. Missouri State Highway Patrol and Boone County, Missouri
April 4, 2023
Summary
The Court reversed summary judgment requiring MacColl to remain registered as a sex offender and remanded because the record presented a genuine issue of material fact concerning whether her completed treatment qualified for a federal clean-record registration reduction. The Court held her 1995 misdemeanor could not independently trigger Missouri registration, classified the offense as a tier I offense rather than a tier III offense, and concluded that eligibility for the federal reduction was not automatic but required factual determination by a court or other tribunal.