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Name: In re Crockett
Case #: A117772
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 01/31/2008
Summary

California court had no authority to require sex offender registration of a juvenile adjudicated in Texas. A Texas juvenile court placed Crockett, a minor, on probation following conviction of a sex offense, and required him to register as a sex offender in Lake County, California where he was to reside with his mother. Crockett applied for probation supervision in California and agreed to live up to the conditions of probation as fixed by both states, and acknowledged notification of his registration requirement. He subsequently failed to register as a sex offender in Lake County, and subsequently in Mendocino County, where he moved. Lake County filed a complaint alleging failure to register, which was dismissed because the court concluded he was not required to register. Mendocino County revoked his probation for failing to register and sentenced Crockett to state prison. Crockett filed a petition for writ of habeas corpus in Mendocino, arguing that his failure to register as a sex offender did not constitute a violation of section 290. The petition was denied. He filed a petition to the appellate court, arguing that the trial court lacked jurisdiction to convict him of failing to register. The appellate court agreed, granted the petition, and vacated the judgment. In re Derrick B. held that a registration requirement in section 290 applied only in adult cases. As a juvenile adjudicated and placed on probation in Texas, Crockett was not required to register as a sex offender in California. California courts had no authority to require registration based on the Texas court order, and the Mendocino County court lacked jurisdiction to convict him of failure to register as a juvenile sex offender in California.