requirement flowed automatically from the fact of conviction. Id. Accordingly, where the requirement to register turns exclusively on the offender’s conviction, the offender receives due process in the criminal proceedings that resulted in the qualifying conviction. Id. The Court concluded that “[plaintiffs who assert a right to a hearing under the Due Process Clause must show that the facts they seek to establish in that hearing are relevant under the statutory scheme.” Id. at 8, 123 S.Ct. 1160. Under a conviction-based sex offender registration statute, due process does not require a pre-registration hearing. Wisconsin’s sex offender registration statute is conviction based, just like Connecticut’s. See State v. Smith, 2010 WI 16, ¶ 37 n. 30, 323 Wis.2d 377, 780 N.W.2d 90 (<HOLDING>). Murphy may not be in the exact position as
recognizing that wisconsins sex offender registration statute satisfies procedural due process requirements in light of connecticut department of public safety v doe holding that a preponderanceoftheevidence standard with respect to sentencing matters satisfies due process requirements holding notice of balance due satisfies notice and demand requirements holding convicted sex offender had not been deprived of liberty interest for purposes of procedural due process challenge to sorp holding such service satisfies due process