UNITED STATES OF AMERICA v. CHARLES D. DOUGLAS
US Court of Appeals for the Fourth Circuit, Traxler, March 9, 2017,
SORNA- Sex-offender evaluation is not an inappropriate condition of probation for someone convicted of failure to register as a sex offender.

Facts
Douglas was convicted in 1994 of sexual abuse of a minor. He was required to register as a sex offender, but in 2002 and 2010 warrants were issues due to his failure to register.
Douglas evaded detection by using a fake name and moving to other states (DC, Kentucky, Texas). He was eventually picked up in Texas and convicted of failure to register.
As a condition of probation, Douglas was required to complete sex-offender evaluation.

Law from the Case
Held: The fact that his conviction was in 1994 did not mean Douglas didn’t require evaluation, particularly where he spent 14 years evading registration (though Douglas claimed he spent the 14 years evading paying child support, not evading registration).