in two ways: Ex post facto challenge In Smith v. Doe, 538 U.S. 84 (2003), the Supreme Court upheld Alaska's sex-offender registration statute. Reasoning that sex offender registration deals with civil laws, not punishment, the Court ruled 6-3 that it is not an unconstitutional ex post facto law. Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen Breyer dissented. However, On July 25, 2008, Doe number two prevailed and the Alaska Supreme Court ruled that the Alaska Sex Offender Registration Act's registration violated the ex post facto clause of the state's constitution and ruled that the requirement does not apply to persons who committed their crimes before the act became effective on August 10, 1994. Due process challenge In Connecticut Dept. of Public Safety v. Doe, 538 U.S. 1 (2003), the Court ruled that Connecticut's sex-offender registration statute did not violate the procedural due process of those to whom it applied, although the Court "expresses no opinion as to whether the State's law violates substantive due process principles." Update: Reynolds V. United States Certiorari to the United States Court of Appeals for the Third Circuit No. 10–6549. Argued October 3, 2011—Decided January 23, 2012 "The Act does not require pre-Act offenders to register before the Attorney General validly specifies that the Act's registration provisions apply to them." State Court rulings Hawaii In State v. Bani, 36 P.3d 1255 (Haw. 2001), the Hawaii State Supreme Court held that Hawaii's sex offender registration statute violated the due process clause of the Constitution of Hawaii, ruling that it deprived potential registrants "of a protected liberty interest without due process of law." The Court reasoned that the sex offender law authorized "public notification of (the potential registrant's) status as a convicted sex offender without notice, an opportunity to be heard, or any preliminary determination of whether and to what extent (he) actually represents a danger to society." Alaska After losing the constitutional challenge in the US Supreme Court in 2002 one of the two Doe's in the case committed suicide. The other Doe began a new challenge in the state courts. Per the ALASKA DEPARTMENT OF PUBLIC SAFETY website: On July 25, 2008, Doe number two prevailed and the Alaska Supreme Court ruled that the Alaska Sex Offender Registration Act's registration violated the ex post facto clause of the state's constitution and ruled that the requirement does not apply to persons who committed their