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Abstract: Just before Christmas 2009, 11-year-old Sarah Haley Foxwell was brutally raped and murdered by a convicted high-risk sex offender, Thomas J. Leggs. Although Leggs was classified as a high-risk offender in Delaware, because of inconsistencies in sex offender classification between states, Maryland identified Leggs as “compliant.” Congress passed the Sex Offender Registration and Notification Act (SORNA) in 2006 to provide minimum registration and notification standards for all jurisdictions.