PA: PARSOL: SORNA’s internet identifier provision is ruled unconstitutionally vague

On Dec. 3, 2025, Judge James J. Panchik of the Court of Common Pleas of Armstrong County, ruled SORNA’s internet identifier provision is unconstitutionally vague. The Com. v. Michael Diebold case arises from a new failure‑to‑provide‑accurate‑registration‑information charge filed after the defendant, in litigating a habeas petition in an earlier SORNA case, disclosed a list of 66 websites he used and a Craigslist email exchange about brush‑cutting services. In response, PSP and the Armstrong County DA treated both Craigslist itself and a Craigslist‑generated relay email address as “internet identifiers” that had to be registered within three business days under 18 Pa.C.S. § 4915.1(a)(3) and 42 Pa.C.S. §§ 9799.15 and 9799.16.​

The defendant moved to dismiss on multiple grounds, including lack of prima facie case, due process, vagueness, de minimis, and malicious prosecution, but the court resolved the case solely on the statutory‑vagueness issue as to “internet identifiers.”​

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NOTE: This is a PA trial court decision and has no precedential value or application to Florida.


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28 thoughts on “PA: PARSOL: SORNA’s internet identifier provision is ruled unconstitutionally vague

  • December 15, 2025

    Just for kicks and Giggles.

    Major Social Media Platforms (User-to-User Interaction)
    – Facebook – Messaging, groups, posts, and comments
    – Instagram – Direct messages, stories, and media sharing
    – TikTok – Video sharing with direct messaging
    – YouTube – Comments, live chat, and community posts
    – Twitter/X – Direct messaging and public posts
    – Reddit – Forums, threads, and private messages

    📱 Messaging & Chat Apps
    – WhatsApp – Text, voice, video calls, and group chats
    – Messenger (Meta) – Integrated with Facebook for direct communication
    – Telegram – Encrypted messaging, channels, and groups
    – WeChat – Messaging, calls, payments, and social features
    – Snapchat – Ephemeral messaging, stories, and video calls
    – Discord – Voice, video, and text chat for communities
    – Signal – Privacy-focused encrypted messaging
    – Line – Popular in Asia for messaging and stickers
    – Viber – Messaging and VoIP calling
    – Kik – Chat app popular with younger audiences

    🖥️ Other Communication-Oriented Platforms
    – LinkedIn – Professional networking with direct messaging
    – Pinterest – Though primarily visual, includes direct messaging
    – Clubhouse – Audio-based social communication
    – Twitch – Live streaming with chat interaction
    Global Leaders (most widely used)
    – Facebook, Instagram, WhatsApp, Messenger, TikTok, Snapchat, Discord, Telegram, WeChat, Twitter/X, Reddit, LinkedIn
    These dominate across multiple regions and demographics.

    🇺🇸 U.S. & Western Popular Apps
    – GroupMe, Nextdoor, Marco Polo, Houseparty (though declining), Signal, Clubhouse
    – Gaming-focused: Xbox Live Chat, PlayStation Network, Steam Chat

    🌏 Regional Giants
    – KakaoTalk (South Korea)
    – Line (Japan, Taiwan, Thailand)
    – VK (VKontakte) (Russia)
    – QQ (China)
    – Hike Messenger (India, though less active now)
    – Zalo (Vietnam)

    🎮 Gaming & Virtual Worlds
    – Roblox Chat, Fortnite Party Chat, Minecraft Realms Chat, World of Warcraft Guild Chat
    – Twitch (stream + chat)
    – Discord (bridges gaming + communities globally)

    🧑‍💼 Professional & Niche
    – Slack, Microsoft Teams, Zoom Chat (work-focused but still direct communication)
    – GitHub Discussions, Stack Overflow Chat (developer communities)
    – ResearchGate, Academia.edu messaging (academic networking)

    YouTube does not currently offer full, built-in direct user-to-user messaging like WhatsApp or Instagram, but it is testing the return of private messaging after removing it in 2019. Right now, communication happens mainly through comments, live chat, and community posts, with limited direct interaction features being piloted in select regions.

    📌 Key Points About YouTube Communication
    – Past Feature: YouTube had a direct messaging system until 2019, but it was discontinued.
    – Current Options: Users interact via video comments, live stream chat, and community posts.
    – Testing Return: In late 2025, YouTube began testing direct messaging again in countries like Ireland and Poland, allowing users to share videos and chat privately.
    – Not Global Yet: The feature is not widely available; it’s limited to test markets and adult users.

    Sorry for the long post.

    Reply
  • December 12, 2025

    I’d never say it has no applicability to FLA and this particular domain (no pun intended) as it could be persuasive for argument sake should it need to be addressed (and given FLA elected officials are always looking for ways to cut PFRs with legal statutes) as well as good strategy to use in similar cases should they arise in the Sunshine state.

    It is a good write up on the case and well considered by the court to put the state back into their place on this topic.

    Reply
  • December 12, 2025

    I feel that de minimis should carry more weight here. Because these arrests over failure to submit an internet ID that one might not even use nor remember can land you in a felony case situation (in FL at least). Then the arresting agency (unless I’m mistaken) can proudly claim it as a ‘sex crime’ related arrest. Until this is clarified they should stop arresting people over this paperwork nonsense altogether. There is a budgetary incentive to keep arrests going in this genre so I guess any chance for an arrest will do.

    In my case I have court ordered nullities to a lot of this, but I don’t feel any safer nor guarded against being wrongfully arrested. When the SHTF it doesn’t care where it lands.

    Reply
  • December 12, 2025

    You say it has no value? Even if in another state, cannot a lawyer state that judge’s ruling as an example in the case they might take on to show that some judges do agree with it being too vague or confusing?

    At some point no companies will allow us to even visit these sites and we can all sit in a chair in our homes and stare at the wall all day because we have nothing to do.

    Reply
    • December 14, 2025

      Yes, they can as it could be seen as persuasive in considerations of the case.

      Reply
  • December 12, 2025

    this section of the law is to be getting more interestering:

    – under Florida if i have a chat discussion over the internet with ai i must register that ai account and name that i use in the chat.

    what if i don’t create an email account or send any but have ai send [email protected] an email how would i even go about following or attempting to in this situation i suppose since i didn’t send the email or use it i’m ok and don’t have to report anything cause technically ai sent the email on my behalf i did not send it.

    things will be getting more interesting lol

    Reply
    • December 12, 2025

      What are you referring to? Like ChatGPT, CoPilot Etc you are not chatting with a human. Why are saying you would have to register that.

      Reply
      • December 12, 2025

        @tearfuleagle

        I agree with you 100% It seems common sense and rationale has been tossed out the window in the pursuit of baseless arrests.

        Reply
        • December 13, 2025

          I am not sure what Screwed is talking about Sarge. But he has not responded. there is no user-to-user conversation there.

          Reply
          • December 13, 2025

            @tearfuleagle

            There are AI companion sites and apps. They require an email to register. The complication is that even though ai is not a person and should not trigger any violation of internet identifier/person to person messaging, but it will be “interesting” to see how law enforcement will twist ai around to fabricate violations and get more arrests.

            common sense would say “no, ai is not a person so it shouldn’t matter”, but we’ll see. ai is a decent enough tool, but it will be used in some pernicious way to get more arrests.

            Reply
            • December 14, 2025

              Thus far we’ve received no reports arrests for unregistered communication with AI.

              Reply
      • December 13, 2025

        “– under Florida if i have a chat discussion over the internet with ai i must register that ai account and name that i use in the chat.” — Where did you come up with that?

        ChatGPT and similar tools do not meet the definition of an “internet identifier” under Florida law or Judge Hinkle’s order. They neither facilitate direct person-to-person contact nor allow users to create profile pages, both of which are required components of “internet identifiers” under Florida statutes and applicable federal caselaw. Only email addresses and “internet identifiers” used for direct person-to-person contact on “commercial social networking websites” need be registered according to both the law and the court order.

        Reply
  • December 12, 2025

    I understand the argument, but I do believe craigslist is considered classified site, and would require registration. Maybe I’m wrong, but that’s just my understanding.

    Reply
    • December 13, 2025

      Actually Craigslist is used to facilitate commerce and should be exempt. That being said you use your e-mail to communicate and not Craigslist in and of itself so that would also exempt it in my understanding
      That is not to say that some county detective would not try to make an arrest or to hassle you for it.

      Reply
      • December 13, 2025

        EBay would be more commerce related, than Craigslist. Craigslist has a classified section, or at least I think they still do. Regardless, you can post job listings, which is some you cannot do on EBay. Virtually all commerce sites, allow communication to some degree, and having to register them, would be ridiculous.

        Reply
        • December 14, 2025

          Tereto

          This is just another scam by the registry department to get us all violated. I am not being insane here but every single year they find more and more add-on’s and restrictions to the point that it is becoming more restrictive than even when I was on probation.

          Eventually we will have to make a detour when driving so that even driving past a school is off limits. And anyone saying that won’t happen, go back a few years in your mind and would you have thought we would have pages and pages of restrictions written in the laws that ONLY registered folks have to comply with?

          A person who murdered someone, once their sentence is over, most of the time they are free to go about their day, other than having a felony on their record. And someone with a murder charge might even have a better chance of getting a job than someone on the registry. And someone who murdered someone, when released from prison, their buddies welcome them back as friends, whereas those on the registry are often rejected by their own families, friends and more.

          Although I admit we all got ourselves into this mess, how in the name of God can they keep retroactively apply all these restrictions on us, plus in Florida, those “Punishments” are all for life. And the more they get away with these new laws, the more embolden they get the next year to further push the envelope.

          Reply
          • December 14, 2025

            @CherokeeJack

            It is an interesting case, and I am purposely not including certain details (involving animals). It is the A.I. aspect that I felt was germane to the conversation. Some of us had real victims, real people whose lives have been changed and some of us not quite. This man used A.I.

            This individual used A.I. that had the likeness of a minor known to him. The grey area is thick here. The child his or herself were not directly harmed by the individual but rather an A.I. that resembled them was used as C.P.

            This is the A.I. slippery slope I am most concerned with.

            They really stacked computer/WIFI Network use charges on him left and right. All things considered I still find the 135yrs sentence egregious. They should offer him the clemency of a firing squad.

            Not sure if it will let me link the article, but here’re the attempt:

            https://www.wtsp.com/article/news/crime/florida-teacher-sentenced-child-animal-sex-abuse-volusia/67-5ef3e79c-2f07-421d-9e5d-a0ef93f5fa4b

            Reply

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