crimes before the act became effective on August 10, 1994. Maryland In March 2013 Maryland Court of Appeals (Highest court of Maryland) decision Doe v. DPSCS declared that Maryland's existing registry laws are punitive in effect, and therefore could not constitutionally be applied retroactively to persons whose crimes pre-dated registration. RSOL's Maryland chapter, FAIR (Families Advocating Intelligent Registries) was part of the Amicus Curiae, testifying for the de facto punitive effects of Maryland sex offender law cited in the decision. This decision was further solidified in 2014 with the "Doe 2" decision. The full impact of these decisions in Maryland is still being effected. Missouri Many successful challenges to sex offender registration laws in the United States have been in Missouri because of a unique provision in the Missouri Constitution (Article I, Section 13) prohibiting laws "retrospective in [their] operation." In Doe v. Phillips, 194 S.W.3d 837 (Mo. banc 2006), the Supreme Court of Missouri held that the Missouri Constitution did not allow the state to place anyone on the registry who had been convicted or pleaded guilty to a registrable offense before the sex offender registration law went into effect on January 1, 1995. and remanded the case for further consideration in light of that holding. On remand, the Jackson County Circuit Court entered an injunction ordering that the applicable individuals be removed from the published sex offender list. Defendant Colonel James Keathley appealed that order to the Missouri Court of Appeals in Kansas City, which affirmed the injunction on April 1, 2008. Keathley filed an appeal with the Supreme Court of Missouri. In response to these rulings, in 2007, several Missouri state Senators proposed an amendment to the Missouri Constitution that would exempt sex offender registration laws from bar on retrospective civil laws. The proposed amendment passed the State Senate unanimously but was not passed by the Missouri House of Representatives before the end of the 2007 legislative session. The same constitutional amendment was proposed in and passed by the Missouri Senate again in 2008, but also was not passed by the House of Representatives by the end of that year's legislative session. As a result, the decisions of the Missouri courts prohibiting the retrospective application of sex offender laws remained intact. The Missouri Supreme Court ruled on Keathley's appeal (Doe v. Phillips now styled Doe v. Keathley) on June 16, 2009. The Court held that the Missouri