Yesterday, the Does’ Brief was filed in the 11th Circuit Court of Appeals in the “Ex Post Facto Plus” challenge.

The appeal raises the following two issues:

  1. Whether the district court erred in refusing to apply the continuing violation doctrine to plaintiffs’ claims against the cumulative effects of 21 years’ worth of increasingly restrictive and mutually-aggravating amendments to FSORNA 2018, where they alleged enactment and enforcement during the limitations period of an amendment that is particularly onerous in context with earlier amendments, and where their claims were not based on the original requirement to register or any other single discrete act?
  2. Whether the district court erred in dismissing the federal and state constitutional claims in plaintiffs’ Second Amended Complaint with prejudice, without granting leave to amend with the proposed Third Amended Complaint?

Much thanks goes to attorneys Val Jonas and Todd Scher for their hard work on this excellent brief and for sticking by the Does. Thanks also goes to the many who worked behind the scenes!

You can read it here: Doe v. Swearingen 11th Initial Brief

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