IN RE: NICK H.
Court of Special Appeals, Woodward, Filed Sept. 29, 2015,

This case poses an interesting judicial interpretation question with regard to the precedent set by a plurality in a superior court.

At the age of 16, Defendant entered a juvenile plea in 2006 to sex abuse of a 5 year old.

In 2010, MSORA was amended to allow for requiring juveniles previously convicted to, after a hearing confirming “significant risk of re-offending”, be forced to register as sex offenders.

This case analyses the plurality in Doe I in which Greene wrote for (Bell, Eldridge), McDonald wrote for (Adkins), and Harrell wrote separately. Barbera dissented.
J. Woodward cites here to his opinion in THOMAS H. QUISPE DEL PINO v. MARYLAND DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONAL SERVICES ET AL..

According to the CoSA, there were two standards at issue in Doe: The “disadvantage” standard and the “use-effects” standard (probably better read as use/effects, but as you will).

Under the “disadvantage” standard, the Maryland constitution prohibits “retroactive application of laws that have the effect on an offender that is the equivalent of imposing a new criminal sanction or punishment.”

Under the “use/effects” standard