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40 Hofstra L. Rev. 269 (2011-2012)
The Adam Walsh Act as Applied to Juveniles: One Size Does Not Fit All

handle is hein.journals/hoflr40 and id is 273 raw text is: NOTE
THE ADAM WALSH ACT AS APPLIED TO
JUVENILES: ONE SIZE DOES NOT FIT ALL
I. INTRODUCTION
Imagine a nine-year-old boy who is forced to watch pornography
and who is subjected to uninvited touching by his relatives. For some,
that is a nightmare, but for Tony Washington, that was his reality.' When
Tony was twelve, his father moved out of their house.2 After his father
left, Tony's mother struggled to make rent, and they were forced to
move from home to home on numerous occasions.3 At sixteen, his
mother had to work at two restaurants, and the closest thing Tony had to
a family was his fifteen-year-old sister, Caylen.4 Tony and his sister
were best friends.5 When they were younger, Tony would look after
Caylen; he would help her with her homework and make sure she ate
dinner.6 However, due to their unstable childhood, Tony and his sister
had a hard time knowing the difference between right and wrong, and on
two separate occasions, they engaged in consensual sexual intercourse.7
On May 9, 2003, Tony pleaded guilty to having consensual sex
with his sister.8 Tony did not know that what he did was wrong.9 Tony
served one month in prison, spent five years on probation, and is now a
registered sex offender for the rest of his life.'0 As a sex offender, Tony
can no longer live within 1000 feet of a school, has to avoid churches,
cannot move without permission of a local officer, and has to inform his
1. See Allison Glock, Unforgiven, ESPN MAG., available at http://sports.espn.go.com/nfl/
news/story?id=5497517 (last updated Aug. 31, 2010).
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