Background
Lance Quintin Longie was required to register as a Tier III sex offender following a Minnesota conviction for first-degree criminal sexual conduct. After his release from custody in May 2022, his supervised-release agent repeatedly explained his registration duties and the process for obtaining approval to travel interstate. Longie registered as living in Moorhead, Minnesota, but then missed a scheduled meeting, traveled to North Dakota, and moved to his mother’s home in South Dakota without registering in either state.
Authorities arrested Longie in South Dakota after approximately 632 days without registration, finding him hiding in a bathroom. A jury convicted him of knowingly failing to register under 18 U.S.C. § 2250(a), and the district court sentenced him to 45 months in prison. On appeal, Longie argued that the district court improperly excluded testimony concerning threats and mistreatment and wrongly refused to instruct the jury on the “uncontrollable circumstances” affirmative defense in § 2250(c).
The Court’s Holding
The Eighth Circuit affirmed. Addressing § 2250(c) for the first time, the court interpreted its language according to its plain meaning and drew guidance from the nearly identical affirmative-defense provision governing failure to appear under 18 U.S.C. § 3146(c). The defense requires circumstances that actually deprive an offender of the ability to comply—not merely circumstances that make compliance frightening, undesirable, or difficult.
The court held that the district court did not reversibly err in limiting testimony from Longie and his mother. The jury heard evidence about alleged harassment, a threat involving a revolver, an assault, and people entering his mother’s home, but Longie never adequately connected those events to an inability to contact authorities or register in South Dakota. The excluded testimony was irrelevant or minimally relevant, and any error was harmless beyond a reasonable doubt given the strong evidence of knowing noncompliance.
The court also held that Longie was not entitled to the requested instruction because the evidence could not support all three elements of § 2250(c). Even assuming the alleged threats were uncontrollable circumstances, Longie failed to show that they prevented registration or that he complied as soon as they ceased. He instead remained unregistered for 632 days, made no demonstrated effort to contact South Dakota authorities, and was still evading arrest when officers found him.
Key Takeaways
- SORNA’s uncontrollable-circumstances defense requires circumstances that actually prevent compliance, not merely fear, harassment, or subjective reluctance.
- A defendant is entitled to a § 2250(c) instruction only when sufficient evidence supports every statutory element of the affirmative defense.
- Longie did not connect the alleged threats to an inability to register and offered no evidence that he attempted to comply once those circumstances ended.
- Any error in excluding portions of the defense testimony was harmless because the government presented overwhelming evidence of knowing noncompliance.
Why It Matters
This decision supplies the Eighth Circuit’s first detailed interpretation of SORNA’s uncontrollable-circumstances defense. By adopting the plain-meaning approach used for the parallel federal failure-to-appear defense, the court set a demanding threshold: the asserted circumstance must effectively deprive the offender of the power to register.
The opinion also underscores the importance of developing a concrete evidentiary record. General allegations of threats or mistreatment will not warrant an affirmative-defense instruction without evidence explaining how those circumstances prevented registration, showing that the defendant did not recklessly create them, and demonstrating compliance as soon as they ended.