In Doe v. State, 189 P.3d 999 (Alaska 2008), the supreme court ruled that sex offender registration is a criminal punishment for purposes of Article I, Section 15 of our state constitution -- the provision that bars the legislature from enacting ex post facto crimes or punishments. In other words, the supreme court held that it is unconstitutional to apply the Sex Offender Registration Act to defendants like Ray whose crimes were committed before the Act took effect. In reaching the conclusion that sex offender registration constitutes "punishment", the supreme court relied heavily on the fact that sex offender registration imposes "significant and intrusive" obligations on a defendant, as well as a "severe stigma". Doe, 189 P.3d at 1009. The supreme court further noted that registration exposes defendants to "profound humiliation and community-wide ostracism", with the attendant possibility that the defendant "will be denied employment and housing opportunities as a result of community hostility". Id. at 1009-1010.