However, finding a violation of this clause here does not mean that it prevents Kansas or other states from passing dangerous sex offender laws. For example, a law that has prospective effect does not violate the a posteriori clause. Weaver, 450 U. S., op. cit. cit., p. 29. Nor does it violate the a posteriori clause whereby a State sentences offenders to the fully permissible sentence, requests successive rather than simultaneous sentences, or invokes recidivism laws to extend the custodial sentence. Moreover, retroactive legislation such as Kansas` does not violate the clause if the restriction it imposes does not constitute a penalty, that is, if Parliament does not simply add a subsequent penalty to a previous penalty. Ibid. delinquency due to sexual violence, committed as a child offender in an institution (§ 6352) and at the end of the 20. 42 Pa. Cons.
Stat. Ann. § 6403).  In order to prove ineffective support in the plea, a person must prove that the outcome of the proceedings would have been different without counsel`s mistakes. Hügel v. Lockhart, 474 U.S. 52, 58-59 (1985); see Saylor v. Nagy, No. 20-1834, 2021 WL 5356030, at *4 (6th Cir. Nov. 17, 2021) (stating that the perpetrator`s litigator lawyer who did not point out to the offender that the consequences of his plea would include lifetime electronic monitoring and sex offender registration does not provide constitutionally deficient representation if lifetime electronic monitoring and sex offender registration are more consistent with the consequences collateral and that the offender is only aware of the direct consequences of the plea. must); United States v.
Cottle, 355 F. App`x 18, 21 (6th Cir. 2009) (on the basis that the court was not required to inform the offender that he had to register as a sex offender and therefore his guilty plea was valid); Washington v. United States, 74 M.J. 560, 561 (A.C.C.A. 2014) (stipulating that the requirement for a military judge to notify an offender that he or she must register as a sex offender before accepting a guilty plea does not apply retroactively); United States v. Riley, 72 M.J. 115, 121 (F.A.C.A. 2013) (stating that the listing of a sex offender for the purpose of determining whether an admission of guilt was voluntary was not a secondary consequence of the offender`s admission of guilt for abducting a minor, and that the judge had not informed the offender that she would have to register as a sex offender on the basis of her plea, led to “an essential basis for questioning the foresight of [the offender`s] admission of guilt”); Rodriguez-Moreno v. State, No. 08-493-TC, 2011 WL 6980829, at *4 (D.
Or. Nov. 15, 2011) (noting that the defence counsel`s failure to inform the offender of the ongoing obligation to register sex offenders associated with his guilty plea did not constitute ineffective support for defence counsel); Mireles v. Bell, No. 06-13706, 2008 WL 126581, p. *3 (E.D. Mich. 11 Jan. 2008) (noting that “the classification, registration and reporting requirements of a sex offender law `are more correctly characterized as collateral consequences of a conviction`” and that “counsel is not ineffective if he fails to inform his client of all the collateral consequences of a plea” and that, therefore, the offender`s lawyer was not ineffective, because he did not inform the offender that he had to register as a sex offender); Taylor v. State, 698 S.E.2d 384, 388-89 (Ga. Ct.
App. 2010) (stating that “failure to inform a client of the need to register as a sex offender is a service flawed by constitutional irregularities” and “requires that criminal accused facing the serious consequences of registering as sex offenders be properly informed”); State v. Flowers, 249 P.3d 367, 372 (Idaho 2011) (the view that the failure of the trial court to inform the offender that he or she should register as a sex offender if pleaded guilty does not invalidate the offender`s plea, since the court is only required to inform the offender of the direct consequences of his or her plea, and the registration of a sex offender is a collateral consequence of an admission of guilt); Menschen v. Cowart, 28 N.E.3d 862, 868 (Ill. App. Ct. 2015) (failure of the trial court to indicate to the offender that he should register as a sex offender if pleaded guilty did not cause the offender to plead guilty unintentionally or involuntarily); Commonwealth v. Thompson, 548 p.w.3d 881, 892-93 (Cy. 2018) (on the basis that the defence lawyer`s failure to inform the offender that a sex offender`s registration would be required if he pleaded guilty to attempted kidnapping violates the offender`s right to effective counsel); Menschen v.
Gravino, 928 N.E.2d 1048, 1056 (N.Y. 2010) (which addresses the issue of whether the sex offender`s admission of guilt was knowingly, willful and intelligent, referring to ineffective assistance to counsel if the trial court did not inform the offender of the consequences of his guilty plea, and emphasizing that sex offender registration is a “side effect”); Menschen v. Nash, 48 A.D.3d 837, 837-38 (N.Y. App. Div. 2008) (the conclusion that the registration of sex offenders is a collateral consequence and therefore failure to inform the offender of the obligation to register does not affect the voluntariness of his admission of guilt); Taylor v. State, 887 N.W.2d 821, 826 (Minn. 2016) (finding that the defense attorney`s failure to inform the defendant of the registration requirements before entering a guilty plea did not violate the accused`s right to effective legal assistance under the United States Constitution and the Constitution of Minnesota); Magyar v.
Staat, 18 Sun.3d 807, 811-12 (Miss. 2009) (noting that since the requirement to register as a sex offender is an incidental consequence of an admission of guilt, the court did not err in failing to inform the offender of his or her obligation to register before accepting an admission of guilt and to rely on case law, which deals with ineffective legal assistance); Staat v. Trammell, 387 P.3d 220, 227 (N.M. 2016) (with the statement that defence counsel “advises the SORNA registration requirement of a plea agreement. is and has long been a prerequisite for effective defence assistance”); State v. Dornoff, 2020-Ohio-3909, No. WD-16-072, 2020 WL 4384223, at *3 (Ohio Ct. App. July 31, 2020) (finding that the offender was not entitled to have his guilty plea quashed if the trial court had not informed him of all the sex offender registration requirements because the offender had not proved that he would not have pleaded guilty, but the trial court did not fully inform him of all the details of the sex offender classification system); State v.
Dantzler, No. 2020AP1823-CR, 2020AP1824-CR, 2021 Wisc. LEXIS 964, to *5 (26. October 2021) (noting that since registration requirements for sex offenders are a secondary consequence of a plea, counsel for the defendant did not provide ineffective assistance to defence counsel if he did not inform the defendant of his obligation to register before filing an admission of guilt). But see People v. Fonville, 804 N.W.2d 878, 895-895 (Mich. Ct. App. 2011) (on the basis that defence counsel was required to inform the offender that he would have to register as a sex offender if he pleaded guilty to the charge of child seduction, and therefore that his failure to do so constituted ineffective support from counsel). Although an increasing number of studies have attempted to capture the recidivism rate of sexual offenders, each study suffers from inherent limitations. First, sexual offences tend to be under-reported, meaning that many of the traditional measures of recidivism, such as re-arrest or reconviction, underestimate the true extent of recidivism among sexual offenders.53 .