Thomas Abdul Holcombe v. United States
SocialSecurity FifthAmendment DueProcess
Whether the Court must resolve splits among and within the circuits because across the country there is no uniformity of prosecution of alleged SORNA violations on the issue of venue?
Questions Presented 1. Whether the Court must resolve splits among and within the circuits because across the country there is no uniformity of prosecution of alleged SORNA violations on the issue of venue? 2. Whether SORNA violates the non-delegation doctrine in the grant to the Attorney General unconstrained discretion to decide to whom SORNA applies without an “intelligible principle” to guide this discretion? 3. Whether SORNA Violates Petitioner’s right to travel, a right which is identified in this Court’s precedent in Saenz v. Roe, 526 U.S. 489, 500 (1999)? 4. Whether the Court of Appeals’ failure to remedy the ex post facto violation is in conflict with this Court’s decision in Collins v. Youngblood, 497 U.S. 37 (1990), as application of SORNA to Petitioner’s circumstances resulted in an increased penalty? i