Armstrong County, PA] On Dec. 3, 2025, Judge James J. Panchik of the Court of Common Pleas of Armstrong County, ruled SORNA’s internet identifier provision is unconstitutionally vague. The Com. v. Michael Diebold case arises from a new failure‑to‑provide‑accurate‑registration‑information charge filed after the defendant, in litigating a habeas petition in an earlier SORNA case, disclosed a list of 66 websites he used and a Craigslist email exchange about brush‑cutting services. In response, PSP and the Armstrong County DA treated both Craigslist itself and a Craigslist‑generated relay email address as “internet identifiers” that had to be registered within three business days under 18 Pa.C.S. § 4915.1(a)(3) and 42 Pa.C.S. §§ 9799.15 and 9799.16.
The defendant moved to dismiss on multiple grounds, including lack of prima facie case, due process, vagueness, de minimis, and malicious prosecution, but the court resolved the case solely on the statutory‑vagueness issue as to “internet identifiers.”
Core statutory interpretation and vagueness holding
The court focused on three clusters of statutory language: “any other designations used in Internet communications or postings” in § 9799.15(g)(8); “any designations or monikers used for self‑identification in Internet communications or postings” in § 9799.16(b)(1); and “designation used by the individual for purpose of routing or self‑identification in Internet communications or postings” in § 9799.16(b)(2). None of these phrases is defined, and the criminal charging statute, § 4915.1(a)(3), does not expressly reference the “internet identifier” language in § 9799.16 at all, even though the affidavit of probable cause imported that wording wholesale.
Applying Pennsylvania’s vagueness standard—that a statute is void only if people of common intelligence must guess at its meaning and differ as to its application—the court concluded that ordinary people might understand they must register email addresses and perhaps user names, but beyond that “have to guess what else is required.” Because the Commonwealth’s theory would extend registration to every website visited, every app used, and every automatically generated relay email, the court found the scheme unconstitutionally vague both facially and as applied.
Rejection of the Commonwealth’s expansive “internet identifier” theory
A central theme of the memorandum is the gulf between the statutory text and the Commonwealth’s operational practice. At the preliminary hearing, Trooper Vaccaro testified—relying on “Megan’s Law requirements”—that “all apps and websites” used with any “internet identifier” must be…
Keeps the state in check from expanding rules without authority to do so.
Good for the judge thank god. Somebody with morals finally chose to speak out against tyranny.
It is absolutely criminal how these laws are created and applied by LE. It is 100% clear the goal is to force the most diligent law-abiding PFR back into prison. The whole scheme is “gotchya” rigged with 0% chance of protecting anyone or preventing future crime.
Bless this judge for not being part of the corruption.
I’ve posted on here a couple times about the “Void for Vagueness” Doctrine. It seems that this could be used on so many, many cases and against many laws.
the void-for-vagueness doctrine requires that >criminal laws be clear enough for an ordinary person to understand what conduct is prohibited ensuring fair notice preventing arbitrary enforcement<.
the supreme court has consistently held that laws must not force individuals to speculate about the meaning of penal statutes, emphasizing that “no one may be required at peril of life, liberty or property to speculate as to the meaning of penal statutes”