In 2013, there were a number of developments in case law, federal legislation, and administrative policies regarding sex offender registration and notification. Two more state supreme courts (Maryland and Oklahoma) held that the retroactive application of sex offender registration and notification requirements violated their state constitution's ex-post-facto prohibition. These decisions are contrary to existing U.S. Supreme Court precedent on this issue (Smith v. Doe, 538 U.S.l 1009 [2003]), which held that retroactive application of sex offender registration requirements is permissible under the Federal Constitution. In Chaidez v. U.S., 133 S.Ct 1103 (2013), the Supreme Court recently concluded that the holding in Padilla v. Kentucky, does not apply retroactively. "Padilla" held that it was constitutionally deficient representation when counsel failed to inform a client that a guilty plea to a criminal charge carried a risk of deportation. Based on "Padilla," a number of cases have addressed the issue of whether counsel's failure to advise a client that a conviction would result in sex offender registration also violates the Sixth Amendment. "Chaldez" undermines this argument. Regarding legislation in 2013, the federal National Defense Authorization Act prohibits the commissioning or enlistment of persons in the Armed Forces who have been convicted of felony sex offenses. Regarding administrative actions, the Department of Defense issued an updated instruction that governs which convictions under the Uniform Code of Military Justice require registration under the federal Sex Offender Registration and Notification Act (SORNA). This report also summarizes two reports issued in 2013 by the Government Accountability Office that reviews the implementation of certain parts of SORNA. 125 notes