Case Citator › United States v. Paul Shenandoah

United States v. Paul Shenandoah

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Third Circuit
Citation
595 F.3d 151
Decided
Confirmed treatments
2
Flagged citations read
30 of 30
Citing cases (total)
30
Treatment dates
2011–2012
Overruled in part
A reviewed court has overruled part of this case’s holding. United States v. Shenandoah has been overruled in part: all 30 flagged citations have been read, and the two confirmed treatments are listed below. The Supreme Court's decision in Reynolds v. United States displaced Shenandoah's holding that federal registration requirements applied to people convicted before SORNA as soon as the statute was enacted.
More on how this was screened

The Third Circuit later recognized that effect in United States v. Stacey. Shenandoah's separate constitutional and notice holdings remain in use.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

30 later cases cite United States v. Paul Shenandoah; 30 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United States v. Paul Shenandoah?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court rejected Shenandoah's rule that SORNA's registration requirements applied to people convicted before the Act as soon as it was enacted, holding that they applied only after the Attorney General specified their applicability.

    Reynolds v. United States · Supreme Court of the United States · filed

    For these reasons, we conclude that the Act’s registration requirements do not apply to pre-Act offenders until the Attorney General so specifies.
    Read the full opinion on CourtListener →

Declined to follow

  • The Fifth Circuit rejected Shenandoah's reading of SORNA for people convicted before the Act, holding that Congress left their coverage to the Attorney General.

    United States v. Johnson · Fifth Circuit · filed

    Yet four other circuits have held that the language of the statute itself applied the provisions to persons with pre-SORNA sex-offense convictions.50 ... We agree with the views expressed in Justice Alito’s dissent and with the Fourth, Sixth, Seventh, Ninth, and Eleventh Circuits—SORNA delegated ... United States v. Fuller, 627 F.3d 499, 504–05 (2d Cir. 2010); United States v. Shenandoah, 595 F.3d 151, 163–64 (3d Cir. 2010);
    Read the full opinion on CourtListener →

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