The Pennsylvania Supreme Court thoroughly discussed an ex-post facto analysis and held that its decision in Muniz applies to offenders whose triggering offense occurred in another state. In Commonwealth v. Muniz, the PA Supreme Court ruled that the Sexual Offender Registration and Notification Act (SORNA) constituted a punitive regulatory scheme that, when imposed retroactively to sex offenders who committed their offenses prior to SORNA’s enactment, amounted to an unconstitutional ex post-facto law. In this case, the defendant committed a rape in 1983 in New York. At the time, neither NY nor PA had enacted a sex offender registration scheme. In 1995, NY passed the “Sex Offender Registration Act” (“SORA”), which became effective in January 1996. PA followed enacted the first version of Megan’s Law in 1995. Like Megan’s Law and SORNA, NY’s SORA applied retroactively, enveloping those offenders who had been convicted of certain triggering offenses (including rape) and who were on probation or parole at the time of its enactment. The defendant complied with SORA during his residency in NY. In 2015, the defendant moved to PA. The relocation triggered automatically a duty to register and report in PA under SORNA’s mandates, which are stricter than those imposed by SORA. One year later, the police arrested the defendant, and he was charged with failure to provide accurate information. The defendant pleaded guilty, and the trial court sentenced him to time in prison. One day later, the PA Supreme Court issued the Muniz decision. The defendant filed a motion to withdraw his plea, and the trial court denied the motion. The defendant appealed, the Superior Court reversed, and the Supreme Court affirmed. The Court ruled that SORNA was enacted in 2012, and, when the defendant moved to PA in 2015, it was applied retroactively to the defendant’s triggering offense, which occurred in 1983. “Obviously, SORNA was applied retroactively. All that remains was the question of whether SORNA is punitive. In 1983, there were no sexual offender registration laws in NY or in PA, and, thus, the defendant faced no punishment beyond his sentence. The same cannot be said for 2015. Because rape is classified under SORNA as a Tier III offense, the defendant was subjected to the same SORNA requirements as was Muniz. We already have ruled in Muniz that those requirements are punitive in nature.”