Donlan v. State – Case Brief Summary (Nevada)

In Donlan v. State (Nev. 2011) 249 P.3d 1231, the defendant, who committed a sex offense in California, was in much the same position as Crofoot, vis-א-vis a registration statute in Nevada.

The defendant claimed Nevada violated the full faith and credit clause by requiring him to register as a sex offender. He had pled guilty to lewd conduct with a child in California. Subsequently, "the California Attorney General ... terminated Donlan's requirement to register in California as a sex offender ... ." (Id. at p. 1232.) The Nevada Supreme Court rejected his full faith and credit claim. It said, "California 'lacks power to dictate the means by which Nevada can protect its public.'" (Id. at p. 1233.)

Consequently, Nevada properly imposed its sex offender registration law on the defendant when he moved to that state, "even if California imposes less restrictive requirements upon sex offenders." (Ibid.)