The Louisiana Supreme Court ruled in Smith v. State that “the sex offender statutes, as amended in 1999, 2006, 2007, and 2008, to the extent that they are applicable to Mr. Smith, are not so obtrusive as to deem them punitive rather than remedial or regulatory.” — So.3d —, 2012 WL 206429 (La.), 2010-1140 (La. 1/24/12) at 17, emphasis added. The Louisiana Supreme Court reached this conclusion based upon the reasoning in Olivieri that sex offender registration requirements may be applied retroactively without violating the prohibition of the ex post facto clause because Mr. . The Court therefore found that retroactive applications of sex offender statutes did not constitute violations of ex post facto clauses because the statutes did not constitute an additional punishment in that the effect was not so obtrusive that the court would find it punitive rather than remedial or regulatory.
