What is the appropriate sentence for a convicted sex offender who failed to register as a sex offender?

Defendant's sentence on count 3 is also appropriate when considered in conjunction with his long criminal history. In People v. Meeks (2004) 123 Cal.App.4th 695, the defendant also failed to register within five days of changing his address. (Id. at p. 706.) Similar to defendant's prior crimes here, in that case the defendant's prior crimes included burglary, rape, robbery, assault with a deadly weapon, and drug possession, which he committed over a substantial period of time and between about 7 to 31 years prior to his conviction for failure to register. (Id. at p. 708.)

The court in People v. Meeks, supra, 123 Cal.App.4th 695 rejected the defendant's characterization of his failure to register as "'de minimis as felonies go,'" stating that "sex offenders present a serious danger to society because of their tendency to repeat their sexual offenses," and that registration of individuals convicted of such crimes protects public safety. (Id. at pp. 709-710.) The court also stated that, "[t]aking into account, as we should, not only the seriousness of defendant's current offense, but also his history of repeated violations of the criminal law that spanned at least 30 years, we cannot say that his sentence is grossly disproportionate to his current offense when viewed in light of his long-standing, and sometimes violent, criminal history." (Id. at p. 709.)

Here, as in People v. Meeks, supra, 123 Cal.App.4th 695, defendant changed his address without registering as a sex offender, and he had committed numerous serious prior property and sex crimes for a substantial period of time before his failure to register. Defendant's sentence for count 3 was not cruel or unusual punishment.

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