Donaldson v. City of El Reno

Summary

The court held that applying the current sex-offender residency restrictions to Donaldson does not violate either the federal or Oklahoma ex post facto clauses because the restrictions are civil regulatory measures rather than punishment. The court limited the prior precedent concerning retroactive extension of registration periods and independently applied the intent-effects factors to the residency restriction. The judgment for Donaldson was reversed and the case remanded to determine unresolved factual and legal questions concerning whether the property is within the statutory distance of a qualifying park. Separate opinions were filed, but they are not summarized here because no separate-opinion records were provided for extraction.