Whether lifetime GPS monitoring of sex offenders based on decades-old convictions and the possibility of future crimes is reasonable under the Fourth Amendment

QUESTIONS PRESENTED FOR REVIEW The State of Wisconsin (like several other states) enacted their lifetime GPS monitoring law for sex offenders in 2008 and made that law retroactive to offenders who committed crimes prior the enactment of the law. The GPS monitoring law imposes lifetime monitoring of offender movements, even after they have fully completed and discharged from the sentence imposed by the court. There is no judicial review or hearing prior to compulsory imposition of the lifetime GPS monitoring. There is no opportunity for an offender to argue or present evidence that they are not a “danger” or risk to the public. A. The lower courts erroneously held, in conflict with the decisions of multiple other federal and state jurisdictions, that lifetime GPS monitoring of sex offenders, based on decades old convictions, and on the assertion that the offender “might” commit another crime at some unspecified future date, was reasonable under the Fourth Amendment. B. The lower courts erroneously held, in conflict with the decisions of multiple other federal and state jurisdictions, that retroactive application of compulsory lifetime GPS monitoring of sex offenders was civil rather than punitive and did not violate Ex Post Facto doctrine. i Il. PARTIES TO PROCEEDING All parties necessary to this action are named in the title page caption. This case previously named Scott Walker as governor of the State of Wisconsin, and Brad Schimel as Attorney General of the State of Wisconsin. Both individuals were removed from office as of 3 January 2019 and have been replaced by Tony Evers and Joshua Kaul. Because this case involves the constitutionality of a Wisconsin state statute, 28 U.S.C. § 2403(b) may apply, and a copy of this petition shall be sent directly to Joshua Kaul, Attorney General of the State of Wisconsin (in addition to Mr. Kaul’s counsel). i ; Ill.