Rufus Chestnut, a registered sex offender, was convicted of violating Georgia’s address-registration law after he left his brother’s apartment and became homeless. The State claimed he failed to give the sheriff 72 hours’ notice of a change in residence, and the trial court imposed a 30-year sentence with five years of imprisonment. The record showed that Chestnut slept in an abandoned trailer, storage units, or behind a store because probation and statutory restrictions prevented him from living with minors or in residences near protected locations. On appeal, he relied on the rule in Santos, which held the former registration requirement unconstitutional for homeless people lacking a street or route address. The Court of Appeals of Georgia reversed. The statute defined an address as a street or route address and expressly stated that homelessness was not an address, so the State had to prove that Chestnut nevertheless had an available address he could have reported. It presented no such evidence. The State could not shift that burden to Chestnut by arguing that his sleeping locations might have had addresses, and his reliance on Santos was not a waived constitutional attack. The conviction was therefore reversed.