
Newsroom·Crisis Support & Safety
Michigan Sex Offender Registry: 20,000 Names Removed
A unanimous ruling, a constitutional reason, and a gap that was there long before it. What survivors are owed next.
A court order can lift a name from a list. It cannot lift what was done.
In two days, more than 20,000 names disappeared from the Michigan sex offender registry. Larry Nassar’s was one of them.
He is still in prison. The ruling behind the removals was unanimous. It rests on a constitutional rule that Michigan lawmakers have now run into twice, and that courts in other states have applied too.
This article covers what happened, why a court would do this, whether other states are doing the same, who is accountable, and five fixes Bloom Ministries is asking lawmakers to make. If you would rather act first and read second, the one action is at the bottom of the page. It takes about forty seconds.
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If This Touches You
Nothing on this page asks anything of you. If you need to talk to someone now, these lines are free, and RAINN’s runs 24 hours a day.
- RAINN National Sexual Assault Hotline: 800-656-HOPE (4673)
- Oregon Child Abuse Hotline: 855-503-SAFE (855-503-7233)
- Bloom Ministries crisis support
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The Short Version
- On Sept. 9, 2026, the Michigan Supreme Court ruled unanimously, in People v. Smith, that the 2021 law behind the Michigan sex offender registry cannot be applied to anyone whose registrable crime happened before July 1, 2011.
- The Michigan sex offender registry held about 43,000 people at the time. More than 20,000 had been removed by Sept. 11.
- Larry Nassar’s name came off the Michigan sex offender registry because his crimes predate 2011. His convictions and prison sentences are unchanged.
- The court did not reject registries. It enforced a ban on adding punishment after the fact.
- Other state high courts have ruled the same way. Pennsylvania shows how a Legislature can write a registry that survives.
- Bloom Ministries is asking for five fixes, including a lifetime tier written the right way and an end to settlements that hide patterns of abuse.
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What the Michigan Sex Offender Registry Ruling Did, and Did Not Do
On Wednesday, Sept. 9, 2026, the Michigan Supreme Court entered its order in People v. Smith. It found that the 2021 version of the Sex Offenders Registration Act, known as SORA, is unconstitutional retroactive punishment for any registrable offense committed before July 1, 2011. The Michigan State Police said it must comply, and that the department did not change the law.
The numbers are large. The Michigan sex offender registry held about 43,000 people who were registered or required to register when the order came down. By Friday, Sept. 11, more than 20,000 had been removed, and state police said the count could still change as the review continued.
What the order did not do matters as much. It did not overturn a single conviction. It did not shorten a single prison sentence. Nassar’s crimes predate 2011 even though his convictions came later, so he came off the Michigan sex offender registry, and he remains in prison under sentences that include a 60-year federal term and a state term of 40 to 175 years.
Three Corrections to What You May Have Seen Online
The ruling was unanimous. Local reporting from Michigan Public and WILX is consistent on this. Posts describing it as the work of one political camp leave that out.
It was a constitutional ruling, not a policy statement about registries. The question was whether lawmakers may add punishment after a crime has been committed. The court had already answered that question for the 2011 law in 2021, and Smith applied the same reasoning to the 2021 law.
The registry still exists. According to state police, anyone whose offense happened on or after July 1, 2011 remains registered. The Michigan sex offender registry is smaller. It is not gone.
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Why the Court Could Not Simply Keep the Names on the Michigan Sex Offender Registry
The U.S. and Michigan constitutions both bar ex post facto punishment, which means a penalty added after the act. Courts separate punishment from civil regulation.
In 2003, in Smith v. Doe, the U.S. Supreme Court held that Alaska’s registry was civil regulation and could apply to older crimes.
That 2003 decision still stands. So the fight moved to what a particular state’s law actually does: its tiers, its reporting rules, its lifetime terms. For the Michigan sex offender registry, the court concluded that the 2011 and 2021 changes added up to punishment, and punishment cannot be added to old crimes.
Prosecutors raised the strongest objection. Eaton County prosecutors said the court could have reverted to an earlier version of the law, and called the decision “deeply concerning.” State police legal guidance says the court held that reviving earlier versions was “not appropriate.”
The part many people miss is who wrote the law behind the Michigan sex offender registry. The Legislature expanded SORA in 2006 and 2011, and amended it again in 2021, and the later versions reached back to past offenses. Courts told Michigan twice that it could not. That is the accountability question, and it is the same one survivors are asking.
How Michigan Got Here
- 1994: Michigan passes the Sex Offenders Registration Act, creating the Michigan sex offender registry.
- 2006 and 2011: the Legislature expands the law, creating harsher measures for registrants and, in 2011, a three-tier system.
- 2016: the Sixth Circuit holds Michigan’s retroactive application punitive in Doe v. Snyder.
- 2021: the Legislature amends the law again, and in People v. Betts the Michigan Supreme Court holds the 2011 law cannot be applied retroactively.
- March 26, 2025: a federal court enters judgment in Does III, finding many parts of SORA unconstitutional, including retroactive changes for people with pre-2011 offenses.
- Sept. 9, 2026: People v. Smith.
- Sept. 11, 2026: more than 20,000 names removed from the Michigan sex offender registry.
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Other States: Is Michigan Alone?
No state we reviewed has cut its registry the way the Michigan sex offender registry was cut, by nearly half in a single order. But Michigan’s collision with the Constitution is not unique. Courts across the country have been splitting on this question for more than twenty years.
States Whose Highest Courts Blocked Retroactive Registration
The U.S. Department of Justice’s SMART Office counted eight state supreme courts that held retroactive registration violated their own state constitutions. Its March 2018 case law update lists seven rulings that still anchor the debate, plus a Missouri ruling later rendered moot:
| State | Year | Case |
|---|---|---|
| Alaska | 2008 | Doe v. State |
| Indiana | 2009 | Wallace v. State |
| Maine | 2009 | State v. Letalien |
| Ohio | 2011 | State v. Williams |
| Maryland | 2013 | Doe v. Department of Public Safety & Correctional Services |
| Oklahoma | 2013 | Starkey v. Oklahoma Department of Corrections |
| Pennsylvania | 2017 | Commonwealth v. Muniz |
SMART also lists a 2015 New Hampshire decision holding that lifetime registration without any chance of review violates that state’s constitution. Federal appeals courts add one more: the Sixth Circuit’s 2016 ruling in Doe v. Snyder is binding precedent in the federal courts of Kentucky, Michigan, Ohio and Tennessee. That table is a 2018 snapshot, and the law has moved in both directions since.
If you live in Kentucky, Ohio or Tennessee, that Sixth Circuit precedent applies in your federal courts too. Your legislature is worth watching.
States That Went the Other Way
Many courts still follow Smith v. Doe and allow retroactive registration. SMART’s update cites decisions from Illinois, Georgia, Idaho, Virginia and Wyoming, an Arizona appeals court, and the Second Circuit for New York. Oklahoma shows how mixed it can get inside one state: after its 2013 ruling, its Supreme Court ruled 5 to 3 in February 2025 that a park-residency restriction could apply to people registered before it passed.
Pennsylvania: The Way Back
Pennsylvania is the most useful comparison for Michigan. After Muniz struck down retroactive application in 2017, the General Assembly rewrote the law in 2018 and added a way to petition for removal after 25 years. The Pennsylvania Supreme Court then held the rewritten law to be civil regulation, not punishment, in Commonwealth v. Lacombe in 2020 and in Commonwealth v. Torsilieri on May 31, 2024.
The lesson is about method, not mercy. A Legislature that writes its registry prospectively, and builds it as a civil system, can keep it. Michigan is in a different position today. Cooley Law School professor Brendan Beery told WILX that lawmakers have no replacement for the Michigan sex offender registry law ready and will likely have to treat violations as a civil matter.
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Who Is Accountable
Accountability here is about offices, not parties. Each of these is a place where a decision was made, and where a different decision was available.
The Legislature. Lawmakers wrote the 2011 and 2021 versions of the Michigan sex offender registry law and applied them to older offenses. By 2021, a federal appeals court had already found the 2011 version punitive. As of the ruling, the Legislature had no replacement ready, and survivors are now waiting on it.
State Rep. Matthew Bierlein, who has sponsored bills to expand the Michigan sex offender registry, called the ruling insulting to victims. He said the Legislature must work with law enforcement and the judicial branch on a new structure.
Congress and federal guidelines. The national SORNA guidelines push states to register people whose convictions predate state laws in several situations, which raises these constitutional questions in every state that follows them.
Prosecutors and plea deals. Registration is sometimes bargained away when a case is pleaded down. A person who never carries a registrable conviction never appears on any list.
Not the courts, and not state police. The Michigan Supreme Court applied a rule that is in the Constitution. State police complied with a court order and sent its concerns to lawmakers. Blaming either misses the people who write the statutes.
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The Gap No Ruling Touches: Who Never Reaches a Registry
A registry lists only people the system has already caught. RAINN’s published figures say that for every 1,000 sexual assaults, 310 are reported to police, 50 reports lead to an arrest, 28 cases lead to a felony conviction, and 25 perpetrators are sentenced to incarceration.
That is the funnel. The Michigan sex offender registry ruling changed who is on a list at the end of it. It did nothing for the people who never reached one.
Powerful defendants have a second exit: the settlement. In December 2022, Congress enacted the Speak Out Act, which makes nondisclosure and nondisparagement clauses unenforceable in sexual assault and harassment disputes. But it covers only clauses signed before a dispute arises. Parties can still negotiate silence in a settlement after the fact.
Bloom Ministries raised confidential settlements in its November 2025 recommendations to Governor Kotek, for cases involving minors. The gap is wider than that. A person who settles with five survivors and signs five confidentiality agreements may never appear on any list, in any court record, or in any database.
We have made the broader case for transparency before, in our pastoral call for truth and justice in the Epstein files. The Bloom Charter says it in six words: no settlement proves harm didn’t happen.
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Five Fixes
1. Write the Serious Tier Once, and Write It Prospectively
For the most serious sexual offenses, registration should be for life. By that we mean offenses involving force, offenses against children, and offenses against people who cannot consent. Bloom Ministries is not asking for a sunset, a clock, or a petition process for that tier.
The Michigan sex offender registry ruling is a warning about method, not about the goal. A lifetime tier that applies to crimes committed after it takes effect does not raise the ex post facto problem. Pennsylvania’s experience shows that a carefully built civil registry can survive review.
Two cautions belong here. Pennsylvania’s law lets some registrants petition for removal after 25 years, and our proposal for the serious tier would not. And New Hampshire’s high court has looked hard at lifetime terms with no review. Lawmakers should test any no-review design against their own state’s constitution before they draft it.
2. End Secret Settlements of Sexual Assault Claims
Four changes, working together. Require every settlement of a sexual assault claim to be reported confidentially to a state repository, with the survivor’s identity sealed. Require a referral to prosecutors when two or more settlements involve the same person. Void any clause that stops a survivor from speaking to police, regulators, or other survivors. Let survivors keep the choice of privacy over their own name and story.
This is not a public list triggered by a settlement. A settlement is not a conviction, and due process matters. But a pattern of settlements against one person is information, and no confidentiality clause should be able to hide it from the people whose job is to investigate.
3. Stop the Clock From Running Out on Justice
A person who was never charged because the limitations period expired never reaches a registry. Statutes of limitations vary widely by state. Bloom Ministries recommends eliminating them for felony sexual offenses against children and lengthening them for the rest.
4. Fund Prosecution and Survivor Legal Help
Cases fail for want of resources, not only for want of evidence. States should fund evidence testing, prosecution units, and no-cost legal representation for survivors, who often face powerful defendants alone.
5. Protect the Falsely Accused, in the Same Law
Bloom Ministries recommends public exoneration notices when allegations are investigated and found unfounded, and case files that clearly separate substantiated, unsubstantiated, and proven-false allegations. Legal consequences should be reserved for fabrication that is clearly established, written so they never discourage genuine reporting.
A system that cannot clear the innocent will not be trusted to hold the guilty. These safeguards belong in the same bill as the lifetime tier.
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Could Oregon Face What Hit the Michigan Sex Offender Registry?
We are not predicting an Oregon ruling. We are saying lawmakers should audit the statute now, while no court order forces their hand. Oregon’s law, ORS chapter 163A, sorts registrants into three levels and already allows some people to ask for relief.
Level 1 registrants may petition the Board of Parole and Post-Prison Supervision for relief, no sooner than five years after supervision ends. The Board must weigh the nature and violence of the offense, the age and number of victims, and the age of the person at the time, according to the Board’s own notice. Anyone convicted of crimes such as first-degree rape or first-degree sodomy is not eligible.
That is a different design from the Michigan sex offender registry, built around individual review. Bloom Ministries’ position is that relief paths like this one should stay out of the serious tier described above.
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What Bloom Has Already Put in Front of Oregon’s Governor
In November 2025, Bloom Ministries submitted policy recommendations to Governor Tina Kotek in six areas. They were mandatory transparency in cases involving minors, independent special prosecutors for conflict-sensitive cases, mandatory reporting by high-risk institutions, survivor-centered justice standards, safeguards for the wrongfully accused, and a statewide accountability commission.
The registry and settlement proposals above go further than that submission. They are new, and they come from watching what happened to the Michigan sex offender registry. Bloom Rising is Bloom Ministries’ advocacy program, and you can follow the rest of this reporting in the Bloom Ministries Newsroom.
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One Action: Sign the Bloom Charter
Every fix above, for the Michigan sex offender registry and for every state watching it, needs something rarer than a good argument. It needs a record of how many people want it. The Bloom Charter is a public declaration with four Pillars and eighteen Articles, and the fourth Pillar, Truth and Accountability for the Silenced, speaks to this issue directly.
It says a survivor is not presumptively disbelieved because the accused is powerful. It says no settlement proves harm didn’t happen, that records of a minor’s exploitation belong to the public, and that passing a transparency law is not the same as obeying it. Article 17 is titled Transparency Over Protection of the Powerful. Article 9 is Equal Enforcement of Existing Law. The founder’s own account of why the Charter was built is in the Newsroom.
Sign the Bloom Charter. It takes about 40 seconds.
No account is needed. Your email is never shown. If visibility isn’t safe for you, sign with a first name only. Founding names are listed in the order they arrive.
If you want to do more than sign, join the Bloom network.
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Sources and Corrections
Sources were checked on Oct. 1 and 2, 2026. Court holdings come from the Michigan State Police legal update and the U.S. Department of Justice SMART Office. Numbers for the removals come from the Michigan State Police.
Errors are corrected in place, with the date noted here.
- Michigan State Police: official statement on compliance with the court order
- Michigan State Police: Legal Update No. 172 (09/2026)
- ACLU of Michigan: SORA background and litigation history
- Michigan Public: removals following the order
- WILX: ruling explained
- U.S. DOJ SMART Office: case law update, March 2018
- Smith v. Doe, 538 U.S. 84 (2003)
- Commonwealth v. Torsilieri (Pa. 2024)
- Oregon Revised Statutes, chapter 163A
- Speak Out Act, Public Law 117-224
- RAINN: criminal justice system statistics
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Frequently Asked Questions
No. The ruling removed his name from the Michigan sex offender registry. It did not touch his convictions or his sentences.
No. It held that the 2021 law cannot be applied to people whose registrable crimes happened before July 1, 2011, because doing so adds punishment after the fact.
Reporting from several Michigan outlets describes it as unanimous. It rests on the constitutional ban on retroactive punishment.
Doing so would add punishment to old crimes, which is what the court barred. Its order also held that reviving earlier versions of the law was not appropriate. Lawmakers can write a new law that applies going forward, and the state could ask the U.S. Supreme Court to review the decision.
No. Alaska, Indiana, Maine, Maryland, Ohio, Oklahoma and Pennsylvania all had high-court rulings against retroactive registration, and the Sixth Circuit’s ruling covers Kentucky, Michigan, Ohio and Tennessee. Other states have gone the opposite way.
For crimes committed after the law takes effect, yes. Pennsylvania’s rewritten registry, which includes lifetime terms for the top tier, was upheld in 2024.
Some, under ORS 163A.125. Level 1 registrants may petition the Board of Parole after at least five years, with disqualifying offenses. Bloom Ministries wants relief paths kept out of the serious tier.
Bloom Ministries is a registered 501(c)(3) nonprofit, and this reporting is free to read and always will be. The most useful thing you can do is sign the Bloom Charter. Sending this article to one person who needs it does real work too.
This article is advocacy and analysis based on public sources. It is not legal advice. Bloom Ministries is a registered 501(c)(3) and does not endorse or oppose candidates for office.
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