 In 2013, Gorsuch joined a unanimous panel finding that intent does not need to be proven under a bank fraud statute.That ruling was affirmed by a Supreme Court unanimous in judgment in "Loughrin v. United States" (2014).In 2015, Gorsuch wrote a dissent to the denial of rehearing "en banc" when the Tenth Circuit found that a convicted sex offender had to register with Kansas after he moved to the Philippines.