context: Other Factors None of the other Mendoza-Martinez factors supports a finding that the CT-SORA is punitive in fact. The burdens of registration and ongoing address verification are not the type of affirmative disability or restraint suggestive of a punitive sanction. As Doe pointed out, the Supreme Court has upheld civil sanctions with burdens much more onerous than those at issue here.
citation_a.signal: see also
citation_a.parenthetical: rejecting an "as applied" challenge to Washington's civil commitment statute
citation_a.sentence: Doe, 120 F.3d at 1279 (citing, inter alia, Kansas v. Hendricks, 521 U.S. 346, 117 S.Ct. 2072, 138 L.Ed.2d 501 (1997) (upholding involuntary civil commitment sanction against an Ex Post Facto Clause challenge)); see also Seling v. Young, — U.S. -, 121 S.Ct. 727, 148 L.Ed.2d 734 (2001) (rejecting an “as applied” challenge to Washington’s civil commitment statute).
citation_b.signal: no signal
citation_b.parenthetical: upholding involuntary civil commitment sanction against an Ex Post Facto Clause challenge
citation_b.sentence: Doe, 120 F.3d at 1279 (citing, inter alia, Kansas v. Hendricks, 521 U.S. 346, 117 S.Ct. 2072, 138 L.Ed.2d 501 (1997) (upholding involuntary civil commitment sanction against an Ex Post Facto Clause challenge)); see also Seling v. Young, — U.S. -, 121 S.Ct. 727, 148 L.Ed.2d 734 (2001) (rejecting an “as applied” challenge to Washington’s civil commitment statute).