In United States v. Ambert , the 11th Circuit reviewed and rejected all of the major constitutional challenges to SORNA prosecutions under 2250(a). I had never heard of this case before, perhaps because the defendant was represented by a private attorney. Here is how the 11th Circuit addressed the Commerce Clause argument:
We have not had occasion to address this issue, although several district courts in this Circuit have done so. Most have found SORNA to be a proper regulation under Congress’ commerce power.... One district court, however, found that SORNA, 42 U.S.C. § 16913 and 18 U.S.C. § 2250, exceeded Congress’ commerce clause authority. United States v. Myers, 2008 WL 5156671 (S.D. Fla. Dec. 9, 2008) (unpublished).... Section 2250 is a proper regulation falling under either of the first two Lopez categories because it regulates both the use of channels of interstate commerce and the instrumentalities of interstate commerce.... Plainly, § 2250 focuses on sex offenders, like the defendant, who travel in interstate commerce. In this focus, SORNA is analogous to a statute prohibiting church-based arson “in or affecting interstate or foreign commerce” upheld by this Court in Ballinger, and to the Mann Act prohibiting the transport of women “in interstate commerce” for an immoral purpose, upheld by the Supreme Court long ago in Caminetti v. United States, 242 U.S. 470, 491 (1917).