At the time Dandridge committed his offense, there was no offender registration requirement in Kansas. Because offender registration is part of a criminal sentence and because Dandridge must be sentenced based on the law in effect at the time he committed his crime, we conclude the district court erred by ordering Dandridge to register as a sex offender. Accordingly, we vacate Dandridge's sentence and remand for resentencing with directions that the district court refrain from imposing registration requirements under KORA. We do not need to reach Dandridge's argument that the current version of the KORA violates the Ex Post Facto Clause of the United States Constitution.The nature of offender registration requirements is a very hot topic and will likely be dealt with in many other cases in the not-too-distant future.
[Update: the state did not file a PR and the mandate issued on March 27, 2014.]