Decisions by Kansas Supreme Court released April 22, 2016, on Offender Registration related cases.
John Doe vs. KBI and JO County Sheriff and State vs Redmond and State vs Buser: The 2011 version of the Offender Registration Act are punitive in nature, not administrative, and cannot be applied retroactively.
But in State vs Petersen-Beard the court rules lifetime registration for sex offenders does not constitute punishment. The key difference in this case and those listed above appears to be the lifetime registration.
In State vs Charles the Court overturned a requirement to register as a violent offender ruling the Offender Registration Act is punitive due to the public disclosure requirements. As a result the offenders requirement to register was overturned because Apprendi applies if offender registration is punitive, thus requiring the decision to register to be made by the trier or fact, in this case a jury. However, the judge made the determination on registration in this case.