Registry Fees Fact Guide
By: Derek W. Logue
Created: 2 Nov. 2011, Updated 27 Aug. 2026

NOTICE! INFO ON REGISTRY FEES CAN BE FOUND IN THE STATE LAW SUMMARY SECTION OF MY BOOK, YOUR LIFE ON THE LIST. THIS PAGE WILL REMAIN BUT THE INFO REGARDING THE STATE LAWS WILL BE REMOVED FROM THIS PAGE ON 6/30/2025

Also worth noting, local-level laws may include registration fees no covered by state laws. Information on some local-level laws can be found on my LOCAL-LEVEL LAWS page. 

INTRODUCTION

“It’s not that I wouldn’t be for it because offsetting the costs to the taxpayers is a good thing. I just don’t think the majority of them can afford to pay, and they’ll quit paying, quit registering and quit showing up and be a bigger problem.” — Polk Co. FL Sheriff Grady Judd on why registry fees are a bad idea. [1]

Registration fees are becoming popular in a select growing number of locations. Perhaps the biggest story on this issue in recent memory is the ordinance proposed by the city of Lake Charles, LA, which would have increased yearly registration fees to $600 per year. As of this writing, the law is on hold due to a temporary injunction [2].

Obviously, registry fees and the fear over possible legal trouble for failing to pay fees is a very real concern. Some state laws consider failure to pay registry fees part of the criminal charge of “failure to register [3].” Exacerbating the possibility of arrest for failure to pay fees is due to the fact that registrants have far higher rates of unemployment than the average citizen. In Oklahoma, “nearly 40%” of registrants are considered “unemployed, disabled, or retired [4]”; Washington State’s unemployment rate for registrants was 25% in 2005, with a 9% rate of homelessness [5].

While many locations have these laws, is it constitutional? There have been few stories regarding sex offenders arrested for failing to pay fees, and even fewer court cases addressing the fees. This article will cover the very sparse commentary on this subject.

HORNER v. GOVERNOR OF NEW HAMPSHIRE

In 2008, Philip Horner argued before the New Hampshire Supreme Court that imposing a semi-annual fee of $17 amounted to “disproportional taxation,” while the state argued that the fees were regulatory. The justices sided with the state, agreeing the fees are regulatory measure and that the “$17 semi-annual charge imposed upon sex offenders is not intended to raise additional revenue but, rather, is used solely to support a governmental regulatory activity made necessary by the actions of those who are required to pay the charge [6].” The fees are seen as the registry itself, a “regulatory” measure which was upheld by the 2003 Smith v. Doe decision [7]. By arguing the law was a tax and not a fee, this case seemed doomed to fail.

EASTERLING V STATE OF FLORIDA

This case involved a life without parole sentence for a mere probation violation for not having a $10 registration ID card. Because Easterling made every effort to comply with the law, at least the registration fee violation was reversed by the First District Court of Appeals. Below is the case summary:

“Easterling was convicted (by plea) of three counts of sexual battery on children under the age of 12 and sentenced to two years’ community control and sex offender probation. Easterling was charged with violating his community control in four respects by: (1) failing to remain at liberty without violating the law by failing to register and obtain an identification card denoting his sex offender status from the Department of Highway Safety and Motor Vehicles (DHSMV) within 48 hours of his release from prison as required by section 944.607, Florida Statutes (2007); (2) failing to follow the lawful instructions of his probation officer directing appellant to register as a sex offender with the DHSMV within 48 hours of his probation; (3) failing to be truthful with his probation officer by omitting necessary facts regarding his failure to obtain the required identification card from the DHSMV; and (4) leaving his home and visiting the DHSMV without his probation officer’s permission.

The uncontradicted evidence demonstrates Easterling made a good faith effort to register and obtain a license in accordance with section 944.607, Florida Statutes. The only reason he did not complete the registration was because he lacked $10 to obtain a new license. In fact, Easterling obtained the license after attempting to comply with the requirement three days later, as soon as he had obtained the necessary funds. While the trial court found that appellant could have asked the probation officer for the money, merely because he did not take the wisest course of action, we cannot say the failure to register was willful and substantial. Van Wagner v. State,677 So.2d 314, 317 (Fla. 1st DCA 1996) (holding where a probationer makes reasonable efforts to comply with a condition of probation, the violation cannot be deemed willful). Because we determine that Easterling made a good faith effort to comply, we must also reverse the violation relating to failing to follow the lawful instructions of his community control officer.

Based on the foregoing, we affirm the finding of violations as to two conditions of community control, but we reverse as to the two charges concerning Easterling’s failure to register. Because it is not clear from the record whether the trial court would have imposed the same sentence based on the remaining violations, we reverse and remand for reconsideration of the revocation and sentencing decisions [8].”

OREGON’S REGISTRY FEES LAW

A recent article at Oregon’s Library of Defense Blog offers a very good assessment of Oregon’s Registry fee law:

“ORS 181.598 requires the assessment of a $70.00 fee for sex offender registration. Sex offenders must pay that fee in the same sense that any of us must pay money we legally owe. However, recent case law makes it fairly clear that failure to pay the fee should not prevent registration and it certainly should not form the basis of a charge of failure to register.

ORS 181.595-597 explain who is required to register as a sex offender. ORS 181.599 creates the crime of failure to report as a sex offender. It requires making the report, signing the registration form, and submitting to fingerprinting and photographing. It does not mention a fee.

The fee comes from ORS 181.598, which requires the Department of State Police to assess a $70 fee. But ORS 181.599 does not require the person to pay it.

In State v. Depeche, 242 Or App 147, 252 P3d 861 (2011), the defendant failed to provide proof of his address while registering. The court held that, because providing verification is not required by ORS 181.899, the defendant had not failed to register by failing to provide proof of his address. Rather, the defendant merely has to show up and try to report in order to avoid liability. Similarly, ORS 181.899 does not require payment of the fee, it just requires the police to ‘assess’ it. If the person hands over the form, signs it, and submits to photographs, I don’t think any crime arises for refusing to pay. (But I’d probably advise my own clients that they should pay anyway).” [9]

(You can refuse to pay the fees in Oregon, as they are a civil penalty. But as it is a civil penalty, thr state can garnish wages or take it out of income taxes.)

TYLER V. STATE

A blog post by Orlando Criminal Defense Attorney John P. Guidry II covers the recent case of Tyler v. State [10]

Remember Obama Care, with a requirement that all American citizens be required to buy something? Is there anything in the constitution that requires a citizen pay for anything? Well, if you’re a convicted sex offender, especially here in Orlando (where the sex offender task force seems to work around the clock) you’ll be paying registration fees for the rest of your life, even if you’ve already served all of your sentence. Hum.

This is America, right? Let’s say you’re convicted of possession of child pornography, once your “debt” is paid to society via a prison sentence and/or probation, it’s over, right? Wrong. For the rest of a sex offender’s life, he must report his whereabouts in person to the local sheriff’s office. In addition, with each change of address (even temporary) he must report to the sheriff’s office and be photographed, fingerprints rolled, and provide additional housing information. After sheriff’s duties are completed–it’s not over–it’s the beginning of paying fees to the Department of Highway Safety and Motor Vehicles.

Supposedly, poverty is no reason to put somebody in prison. But, sex offenders are forced to pay “fees” forever. The fees are $25, to update driver’s license info within 48 hours of any change in permanent or temporary residence. Remember, “temporary” means staying somewhere for five (5) days total, during a calendar year!?!? Is this constitutional? Yep. A one week vacation requires registration, and fees when you get there. Imagine spending the first day of every vacation at the sheriff’s office, then at the DMV? Shoot me now! Then, when you return home, more registration fees to tell them you’re back! Wow. Driving two hours to visit mom and dad for the week? Register there. Pay fees. Drive home, let them know you’ve returned, pay fees again.

Is all this fee paying constitutional? This issue was “sort of” addressed in Tyler v. State, 2011 WL 3300165 (2nd DCA 2011), where the defendant was convicted of failing to register as a sex offender because he did not obtain an updated driver’s license after changing his residence. He challenged the constitutionality of forcing a sex offender to pay for constant updates to his driver’s license. Tyler claimed that he could not afford to update his information, and it’s unconstitutional to force him to do so. (after all, who’s hiring sex offender’s these days?)

The good news is that it seems as though the Tyler court may have been willing to tackle this issue favorably, but the facts weren’t ripe because Tyler presented no evidence of his inability to pay the fees. The court noted that “no law requires a typical resident, or even a typical felon, to obtain a driver’s license or identification card. On the other hand, sexual offenders such as Tyler are legally compelled to obtain this documentation every time they change their residences, and they are expressly required to pay for it”, Id at 3.

The court did not buy the prosecutor’s argument that this law is constitutional, noting that “we disagree with the State’s assertion … that his constitutional challenge has already been resolved against him by Florida’s appellate courts. None of the cases cited by the State, either in the circuit court or here, has upheld the statute against a constitutional challenge premised on the defendant’s indigence….Neither have we found such a case.” Id. at 4.

Supposedly, a Registrant may be removed from registration requirements after many years have passed, but good luck getting a judge to do so (hey, it’s worth a try, the worst thing they can do is say no).

DOE, SEX OFFENDER REGISTRY BOARD NO. 10800 v. SEX OFFENDER REGISTRY BOARD

Like the Horner case, this court upheld an decision that the registry fees are not “disproportionate taxation,” but it is the court’s assertions that pique interest. They claim the registration scheme actually benefits the offender. I beg to differ:

We add that the regulatory scheme governing the registration of sex offenders is not wholly devoid of any benefit to a sex offender because it provides the offender with the opportunity to alter his classification level or terminate his registration obligation. Because the risk to reoffend and the degree of dangerousness posed by a sex offender may change over time, a level two or level three sex offender may file with the board, after three years from the date of his final classification, a motion for reexamination of his classification level.

So let me get this straight– the court actually determined the registry scheme actually provides benefit for registrants because they can theoretically go to court to get off the registry? Unbelievable.

MOST REGISTRANTS CANNOT PAY THESE FEES

The following comments from the Marion, IL Police Department already sum up the hardships caused by these fees:

“The majority of sex offenders are either low income, or on disability, unemployed or living paycheck to paycheck like everybody else. With the fee increasing, it’s been a hardship on everybody,” explains Christina Burns, Marion police department’s records coordinator. Burns says only about five to ten percent of the city’s sex offenders can afford to pay the $100 annual fee. She admits it’s difficult for them to hold down a job due to their situation. “If they can’t maintain their job, they’re certainly not going to maintain or have accessible money to pay a fee that went from something that could be construed as quite miniscule to 100 dollars a year.” [12]

As a result, many districts in Illinois have not enforced these fees or waived them due to indigence. One more recent article gives an idea how the fees are being divided:

“The $100 is broken down between four agencies,” Breeze said. “Thirty dollars is kept by the Mt. Vernon Police Department; $10 is sent to the Sex Offender Management Board Fund, which is part of the state treasurer’s office; $30 goes to the Illinois State Police Sex Offender Registration Fund, since the State Police oversee all registration in the state; and $30 goes to the Illinois Attorney General Sex Offender Awareness Training and Education Fund.” [13]

Who says the registry is not an industry?

In 2012, Illinois introduced HB4670, which includes the following provisions:

  1. Those who cannot pay the $100 annual fee up front can pay in installments
  2. Those who cannot pay the fee can perform 100 hours of community service
  3. Failure to pay is a class C felony [14]

The bill stalled out but was reintroduced in the 2013 session.

DOUBLE FEES

If you live on a Native American Reservation, you could have to register, and pay those fees, twice. At least, if you live on Saginaw Chippewa land in Isabella, Co., MI. So even the Native American tribes are using the registry as a money-making venture:

“Sex offenders in much of Isabella County now have to register and report twice, once to the state and separately to the Saginaw Chippewa Indian Tribe. Those who register with the state but fail to report to Tribal Police could face federal prosecution and up to $5,000 in civil fines in Tribal Court. Tribal Council adopted a sex offender registry ordinance in July and has been notifying law enforcement, registered offenders, schools and local employers. Federal law requires Tribes to either enact their own registry or delegate their authority to the state. Besides prosecution and civil fines, the Tribal ordinance threatens “exclusion,” which could mean forcing violators to move from the five townships and half of two others that comprise Indian Country. Under agreements signed just shy of a year ago, the state recognizes the townships of Deerfield, Denver, Isabella, Nottawa and Wise, plus the north halves of Chippewa and Union, including part of Mt. Pleasant, as Indian Country as defined by federal law.

Local police and attorneys are fielding calls from confused sex offenders and say the process is redundant. City, state and county officers already confirm addresses of sex offenders and track down those who do not comply. “These same sex offenders are now required to appear in person at the Tribal Police Department to perform this same verification procedure as well as pay a fee,” said Mt. Pleasant Police Capt. Tom Forsberg. “This is a clear duplication of effort.” There have been no talks about sharing verification duties, and Tribal police officials seldom attend meetings held between local police agencies, police officials said. [15]

DOE v. RAEMISCH, 895 F.Supp.2d 897 (2012)

There was a small glimmer of hope, as one court, as one court ruled the annual fee, declaring “imposition of the $100 annual fee on Plaintiffs pursuant to Wis. Stat. § 301.45(10) constitutes punishment in violation of their rights under the ex post facto clauses of the United States and Wisconsin constitutions and enjoining Defendants from assessing or collecting such amount from Plaintiffs [16].

However, the 7th Circuit court not only overruled the US District Court decision and claiming the fees were not “unlawful fines,” the Court determined the plaintiffs could not proceed anonymously, despite the hardships placed upon public disclosure of their identities [17].

DOES v. SNYDER

In Snyder [18], the US District Court, citing Wright v. McLain [18], determined Michigan’s $50 annual fee is a tax as defined by the Tax Injunction Act (28 U.S.C. § 1341). To determine whether an assessment constitutes a tax, courts utilize a three-factor test: “(1) the entity that imposes the assessment; (2) the parties upon whom the assessment is imposed; and (3) whether the assessment is expended for general public purposes, or used for the regulation or benefit of the parties upon whom the assessment is imposed. Because the Court determined the $50 annual fee was a “tax,” the court determined it was barred from assessing whether the fee violated ex post facto.

Mueller v. Raemisch, 740 F. 3d 1128 – Court of Appeals, 7th Circuit 2014

This court distinguished between a fee and a fine and concluded that the plaintiffs had not presented sufficient evidence to conclude that the sex offender registration fee was, in effect, a fine. This doesn’t necessarily mean the argument will not work; in this case, the courts simply ruled the plaintiffs didn’t present a strong enough argument against the registry fees:

“But what about the $100 annual registration fee? The state calls it a fee, the plaintiffs a fine. Fee and fine are two quite different animals. A fee is compensation for a service provided to, or alternatively compensation for a cost imposed by, the person charged the fee. By virtue of their sex offenses the plaintiffs have imposed on the State of Wisconsin the cost of obtaining and recording information about their whereabouts and other circumstances. The $100 annual fee is imposed in virtue of that cost, though like most fees it doubtless bears only an approximate relation to the cost it is meant to offset. A fine, in contrast, is a punishment for an unlawful act; it is a substitute deterrent for prison time and, like other punishments, a signal of social disapproval of unlawful behavior.

Labels don’t control. A fine is a fine even if called a fee, and one basis for reclassifying a fee as a fine would be that it bore no relation to the cost for which the fee was ostensibly intended to compensate. That is a common basis on which a fee is reclassified as a tax… But it seems acknowledged in this case that if the $100 annual fee is not a bona fide fee, it is a fine rather than a tax.

The burden of proving that it is a fine is on the plaintiffs, and since they have presented no evidence that it was intended as a fine… they cannot get to first base without evidence that it is grossly disproportionate to the annual cost of keeping track of a sex offender registrant — and they have presented no evidence of that either. They haven’t even tried.”

REGISTRY FEE COLLECTIONS LEAD TO ABUSE

In 2013, Rebecca Hord of the Bedford Co. TN Sheriff’s office was arrested for stealing over $10,000 from the Sex Offender registry office. Hord had apparently stolen fees from individuals who paid the registry fees and forged documents claiming the registrants were indigent. “According to an investigative audit by the Comptroller of the Treasury released in late 2013, a cash shortage of at least $31,460 was found in 2012 from the sheriff’s department’s sexual offender registry office (SOR). After Hord was fired, the new SOR questioned a sexual offender regarding $150 in fees the database said he owed. The offender presented a generic, unofficial receipt documenting the payment, but the department had no record and could not trace it to a deposit. Several receipts from sexual offenders also could not be traced to the accounting records of the department, or to the SOR, the audit reported, and an investigation was initiated. The investigation covered the period Jan. 1, 2006, through Dec. 31, 2011. From 2006 to 2011, at least $42,198 should have been collected [20].”

It is no longer enough that registrants are forced to pay registry fees, now registrants should demand an official receipt for paying fees. My advice is if you pay, do so with a check or money order, and demand a receipt for the payment. Of course, if you can claim indigent and not have to pay altogether, that is better, but be sure the authorization comes from the proper person, usually a judge.

“If this were a private industry…Management would say, ‘This isn’t working right.'”

Since 2012, the Massachusetts Sex Offender Registry Board has collected $1.1 million in fees from men and women convicted of sex crimes, but the board has failed to collect another $1.2 million in fees. (This number does not include those who were determined to be indigent and thus not required to pay the $75 annual fee.) “If we were in private industry and you were basically saying, ‘hey, 40 percent of what you think your revenue should be is not being collected,’ management would say, ‘this isn’t working right,'” Rep. Bradley Jones added. Paul Craney of the Massachusetts Fiscal Alliance stated, “Massachusetts is continually ranked as one of the most expensive states to do business in, to live in and here we are passing over a group of people who owe money.” As of June 2015, Massachusetts law does not penalize those who fail to pay the fee, but some legislators are considering passing a law that would penalize non-payment by preventing registrants from getting their car registration renewed by the state. [21]

It is bothersome to compare fee collection as a private industry, and the proposed solution reads like blackmail. Furthermore, denying car registration renewal would simply exacerbate the difficulties registrants face in finding adequate employment, and as a result, more registered citizens will become indigent.

“I don’t have to pay the fee? Maybe I can be lax on the registration.”

When fighting legislation on registry fees, expect hyperbolic statements from legislators desperate to keep the money train from being derailed.

Massachusetts State Senator Bruce Tarr justified proposing stronger laws requiring registrants to pay by claiming those who fail to pay the fee today will fail to register tomorrow. “What are they gonna think about- ‘I don’t have to pay the fee? Maybe I can be lax on the registration.’ We cannot afford to go down that slippery slope with folks that are being required to register for a reason.” [22]

New Hampshire State Senator Dick Marston helped derail a bill that would have abolished the $50 annual fee by claiming abolishing the fee would lead to abolishment of the entire registry (which, in my opinion, would be a good thing). Minutes before the bill was up for a vote, Sen. Marston posted the following blurb on the House Calendar: “There is a provision in the law that would currently allow the fee to be waived if the offender was unable to afford it. The (House Criminal Justice) committee determined that repealing the fee would have resulted in virtually eliminating the registry, which would be a disservice to the citizens of NH.” [23]

State of Kansas v. Sims, No. 114,959 (Kan. 2026)

The Kansas Supreme Court unanimously reversed three convictions against Sims for failing to pay the $20 fee required under the Kansas Offender Registration Act (KORA). The Court’s decision came after years of litigation over whether Kansas could impose criminal punishment for failure to pay a registration fee. Sims had complied with the underlying requirement to register. His problem was that he did not pay the $20 fee. He was ultimately convicted, but the Kansas Supreme Court reversed. Three justices went further in their reasoning and raised a fundamental constitutional question: What legitimate government interest is served by putting someone in prison for failing to pay a $20 administrative registration fee? One Justice wrote that imposing felony criminal liability for failing to pay a $20 administrative fee may be “arbitrary and unreasonable” and may lack any rational relationship to a legitimate government interest. He emphasized that Sims had actually appeared at the sheriff’s office and registered, but was prosecuted because he owed $20. The opinion is particularly significant because the Kansas court recognized that laws must be rationally related to legitimate governmental interests and cannot become unreasonable or oppressive simply because the legislature has enacted them. However, the Kansas Supreme Court did not declare fees unconstitutional in and of themselves. [24]

SUMMARY

The legal history on registration fees is very sparse, but it appears the justification behind the fees relies on the same “regulatory measure” arguments as Smith v Doe. The law is clear that registry fees are not taxes; however, as courts have recently admitted current sex offender schemes are punitive rather than regulatory, chances are the fees would be considered a violation of the Constitution (my argument would include the 8th Amendment regarding excessive fees; see also my civil versus criminal law fact guide).

Because each state is different in penalties for failure to pay fees, it is wise to try to check the laws in your state. Some states have a set criminal penalty attached, others do not. Some states allow indigence status, while others merely accumulate fees like you would run a bar tab. I am including state laws regarding registration fees and penalties. Laws are subject to change and may not be accurate after the next legislative session.

REFERENCES

  1. 9 Investigates uncovers proposed plan to make sex offenders pay yearly fee. WFTV9. Cox Media Group. July 6, 2015. Web.
    <http://www.wftv.com/news/news/local/9-investigates-uncovers-proposed-plan-make-sex-off/nmsMj/>
  2. Theresa Schmidt, “LC sex offender registration law blocked for now.” KPLC-TV 7, August 8, 2011. http://www.kplctv.
    com/story/15228602/lc-sex-offender-registration-law-blocked-for-now, Retrieved Nov. 2, 2011.
  3. See, for example, the Jefferson County, CO Sheriff’s Office website at http://jeffco.us/sheriff/sheriff_T62_R49.htm, Retrieved Nov. 2, 2011. Register as a Sex Offender– If you have been ordered to register as a sex offender, you may do so at the Sheriff’s Office headquarters, Records section. Effective March 1, 2008, the Sheriff’s Office began charging a processing fee for sex offender registrants, pursuant to state law CRS 16-22-108 (7). The initial registration fee is $50; re- registration is $25, and change of address is $25. Fees must be paid in cash, check, Visa or MasterCard. Failure to register and pay the fee may result in a criminal charge for failure to register. For more information, please call 303-271-5855.” See also Louisiana R.S. 15:542-D
  4. Nicole Marshall, “Police say too many Okla. sex offenders unemployed.” Tulsa World, July 4, 2011. http://www.greenwichtime.com/news/article/Police-say-too-many-Okla-sex-offenders-unemployed-1451964.php#ixzz1cbUZbaUn.
    Retrieved Oct. 2, 2011. No longer online.
  5. Government Management Accountability and Performance (GMAP), “What are the challenges to successful offender transition and community safety?” http://www.accountability.wa.gov/reports/safety/20051130/offenders_main.pdf, Retrieved Nov. 2, 2011
  6. Philip S. HORNER v. GOVERNOR, State of New Hampshire and another. No. 2007-668. Argued March 27, 2008. — June
    19, 2008. http://caselaw.findlaw.com/nh-supreme-court/1152751.html
  7. See OnceFallen’s “Civil vs Criminal” article for more on this old civil versus criminal argument
  8. Easterling v. State, 989 So. 2d 1285, 1287 (Fla. 1st DCA 2008), http://www.leagle.com/xmlResult.aspx?xmldoc=In%20FLCO%2020080915051.xml&docbase=CSLWAR3-2007-CURR, Retrieved Nov. 2, 2011
  9. Rankin Johnson IV, “Do Sex Offenders Have to Pay a Registration Fee?” Library of Defense Blog, Sept. 8, 2011. https://mpdtrainer.wordpress.com/2011/09/08/do-sex-offenders-have-to-pay-a-registration-fee/, Retrieved Nov. 2, 2011
  10. John P. Guidry II, “Sex Offenders Will Pay Government Fees Forever.” Orlando Criminal Defense Attorney Blog, Sept. 17,
    2011. http://www.orlandocriminaldefenseattorneyblog.com/2011/09/being-a-sex-offender-costs-lon.html, Retrieved Nov. 21, 2011
  11. DOE, SEX OFFENDER REGISTRY BOARD NO. 10800 v. SEX OFFENDER REGISTRY BOARD, 459 Mass. 603 (2011)
  12. Fanna Haile-Selassie and Jared Roberts, “Many sex offenders not paying new fee.” WSIL-TV3, Dec. 22, 2011. http://www.wsiltv.com/news/local/Many-Sex-Offenders-Not-Paying-New-Fee-136109823.html, Retrieved Jan. 4, 2012
  13. Tesa Culli, “Registered sex offenders to pay fee.” Mt. Vernon Register-News, Dec. 22, 2011. http://register-news.com/local/x191076582/Registered-sex-offenders-to-pay-fee, Retrieved Jan. 4, 2012
  14. Illinois Legislature, HB 4670, http://www.ilga.gov/legislation/BillStatus.asp?DocNum=4670&GAID=11&DocTypeID=HB&LegId=64461&SessionID=84&GA=97
  15. Rick Mills. “NEW: Tribe starts sex offender registry.” The Morning Sun, Oct. 22, 2011. http://www.themorningsun.com/articles/2011/10/22/news/doc4ea37070b7476871538179.txt?viewmode=fullstor, Retrieved Jan. 28, 2012.
  16. Full document info available for download at http://dockets.justia.com/docket/wisconsin/wiedce/2:2010cv00911/54454/
  17. Mueller v. Raemisch, 740 F. 3d 1128 – Court of Appeals, 7th Circuit 2014
  18. Does et al v. SNYDER et al, No. 2:2012cv11194 – Document 103 (E.D. Mich. 2015)
  19. WRIGHT v. McCLAIN, 835 F.2d 143 (1987)
  20. T-G Staff Report. Hord case cited in state audit. Shelbyville Times-Gazette, May 29, 2015. Web. <http://www.t-g.com/story/2199956.html>
  21. All Donelly. Investigation Finds Sex Offenders Are Not Paying Mass. Registration Fees. NECN.com, NBCUniversal Media,
    LLC, June 16, 2015. Web. <http://www.necn.com/news/new-england/Investigation-Finds-Sex-Offenders-Are-Not-Paying-Mass-Registration-Fee-307757351.html>
  22. Ibid.
  23. Chris Dornin. Dornin: Pay $50 a Year Forever … Or Maybe Not. Concord Patch, June 18, 2015. Web. <http://patch.com/new-hampshire/concord-nh/dornin-pay-50-year-forever-or-maybe-not>
  24. Credit to Florida Action Committee for the summary. Read their analysis at: “KS: Kansas Supreme Court Reverses Convictions for Failing to Pay Sex-Offender Registration Fees.” Florida Action Committee, Aug. 25, 2026. Web. <https://floridaactioncommittee.org/ks-kansas-supreme-court-reverses-convictions-for-failing-to-pay-sex-offender-registration-fees/>