ms. baumgartel? ms. baumgartel: mr. chief justice, and may it please the court, sorna's delegation provision grants unguided power to the nation's top prosecutor to expand the scope of criminal laws and to impose burdensome, sometimes lifetime registration requirements on hundreds of thousands of individuals. it combines criminal law-making and executive power in precisely the way that the constitution was designed to prohibit. this delegation is unconstitutional. this delegation can be distinguished from every delegation that has previously been upheld by this court due to a combination of its total lack of standard and the nature and power -- nature and significance of the delegated power. unlike other delegations that this court has approved, sorna has no standard to guide the attorney general's exercise of discretion. justice roberts: well, the government says that they do have a standard and it's the -- apply the prohibition or the requirements in the law to the maximum extent feasible. ms. baumgartel: your honor,

ms. baumgartel, you have four minutes remaining. ms. baumgartel: thank you. just to pick up where my friend left off, i want to emphasize that prior to sorna's enactment, every single state had an existing sex offender registry and those will continue to exist and to require the registration of offenders, regardless of what happens with sorna. individuals like petitioner were required to register under existing state law and they will still be required to register. this was a law whose retroactive application was opposed by the states, which is part of the reason why only 18 states have implemented it. states spoke out against the retroactive application of the law before the attorney general made his determination. and so states themselves, who are the experts in this area having run registration systems for years, don't want this act to be fully retroactive. my friend emphasized that this delegation was all about practicality, but the reality is, is that the attorney general's promulgated rule does not account for practicality in any way, which is further e