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Name: Crofoot v. Harris
Case #: B258365
Court: CA Court of Appeal
District 2 DCA
Division: 6
Opinion Date: 08/26/2015

California was not required to give full faith and credit to Washington State order terminating the requirement that defendant register as a sex offender. In 2000, Crofoot pled guilty in Washington State to communicating with a minor for sexual purposes. He was placed on probation and required to register as a sex offender. In 2014 he obtained an order in Washington terminating the registration requirement (Rev. Code Wash., § 9A.44.140 [requiring registration for 10 years for Crofoot’s offense]). He later moved to California, where he was required to register as a sex offender based on his Washington conviction for the rest of his life. (See Pen. Code, §§ 290, subd. (c), 290.005.) He petitioned for writ of mandate, arguing that California’s refusal to honor the Washington order terminating his registration requirement violates the full faith and credit clause of the U.S. Constitution. The trial court denied his petition and Crofoot appealed. Held: Affirmed. “[T]he full faith and credit clause does not require one state to substitute for its own statute, applicable to persons and events within it, the conflicting statute of another state, even though that [latter] statute is of controlling force in the courts of the state of its enactment with respect to the same persons and events.” (Pacific E. Ins. Co. v. Industrial Acci. Com. (1939) 306 U.S. 493, 502.) It may not be applied to frustrate a state’s “domestic policy” which is intended to apply to persons or events within the state. A state’s sex offender registration law is part of its “domestic policy.” Crofoot’s residency in California creates a state interest in enforcing the registration requirement to protect California citizens. It does not interfere with Washington’s interests under the full faith and credit clause, as that state’s interest in Crofoot is attenuated by his move to California.