231690P.pdf   11/20/2023  United States  v.  Michael Coulson
   U.S. Court of Appeals Case No:  23-1690
   U.S. District Court for the Northern District of Iowa - Central   
   [PUBLISHED] [Melloy, Author, with Loken and Kelly, Circuit Judges] 
   Criminal case - Criminal law. The categorical approach applies to the 
   categorization of a defendant's underlying sex offense for purposes of 
   determining the applicable sentence upon their conviction under the Sex 
   Offender Registration and Notification Act; defendant's offense of 
   conviction, forcible pandering in violation of Article 120c(b) of the 
   Uniform Code of Military Justice, is unambiguously broader in scope than 
   the SORNA comparators; defendant's SORNA conviction is reversed and the 
   matter is remanded for further proceedings. Judge Loken, dissenting.