“as did her clients in their testimony.”
I sure wish more Ex post FTR defendants would opt for trial.
Most fail to realize they can put the law itself on trial.
By definition they are easily identified even by laymen (jury)
“On its face ex post” is a big problem for the other side. & they will move to quash constitutional argument via limine. The phrase should be used AMAP in the presence. A direct comparison can be made between what the NOTICE OF CONVICTION content reveals and the statutes applied.
State cannot extricate itself from the ex post stat but motion to exclude the staT based on conviction date which BTW could be read plainly to absolutely exclude. My state law uses December 26, 1993. Since notice date always predates Act implementation date, reasonable doubt rears defacto. Depending on states choice for admin of SOR another issues favorable develops. DOC, DPS defendant are advantaged precisely because it’s the same agency used to punish AND term of commitment length plainly conflict.
You don’t logically call a plumber to do your electrical work & Who pays more than they were told they had too?
Pro se defendants can expect some leeway in cross IF foundations laid properly during states open.