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People v. Chatman

Filed 2/1/18 IN THE SUPREME COURT OF CALIFORNIA THE PEOPLE, ) ) Plaintiff and Respondent, ) ) S237374 v. ) ) Ct.App. 1/1 A144196 JODY CHATMAN, ) ) Alameda County Defendant and Appellant. ) Super. Ct. No. 140542 ____________________________________) Anyone convicted of a felony in California suffers consequences. Even long after a defendant completes a term of incarceration or probation, some of these consequences –– such as ineligibility for certain employment licenses –– persist. To ease this ongoing burden, individuals can seek a certificate of rehabilitation. But not all convicted felons are eligible on an equal basis for such certificates. While former probationers and former prisoners are both eligible, former probationers face different eligibility criteria after they have been granted relief under Penal Code section 1203.4,1 which allows former probationers to move for their conviction to be dismissed upon successful completion of probation terms. Once former probationers receive the benefit of having their convictions dismissed under section 1203.4, another provision –– section 4852.01 –– renders them ineligible for a certificate of rehabilitation if they are subsequently incarcerated. (See § 4852.01, subd. (b).) In contrast, former prisoners –– whether 1 All unlabeled statutory references are to the Penal Code. 1 subsequently incarcerated or not –– face no such restriction. (See id., subd. (a).) The question in this case is whether these eligibility criteria survive an equal protection challenge under the federal and state constitutions, which in turn depends on whether the criteria survive rational basis review. The Court of Appeal held that section 4852.01’s separate requirements governing former probationers whose convictions were dismissed under section 1203.4 are categorically irrational, and therefore deny petitioners equal protection of law. Bearing in mind that the scheme at issue is subject to neither heightened nor intermediate scrutiny, we conclude otherwise: section 4852.01’s eligibility criteria survive rational basis review. The Legislature’s decision to provide former probationers access to certificates of rehabilitation serves the laudable goal of decreasing the unfortunate aftereffects of felony convictions on those who achieve rehabilitation. But while certificates provide substantial benefits to rehabilitated felons, adjudicating eligibility for them depends on the state’s expenditure of significant judicial and executive branch resources. In providing this costly benefit only to former prisoners and former probationers who have not been subsequently incarcerated, the Legislature engaged in a line-drawing that –– while perhaps not emblematic of the ideal rehabilitative system –– embodies a sufficiently rational determination regarding distribution of resources. Distinctions between former probationers and former prisoners underscore why. Former probationers, as opposed to former prisoners, can seek some relief from the effects of their convictions through section 1203.4, and so exhibit somewhat less relative need for certificate of rehabilitation relief. Moreover, when the Legislature first provided access to certificates of rehabilitation in 1943, it did so only for former prisoners. Only in 1976 was the benefit extended to former probationers not subsequently incarcerated. From the legislative history, it 2 appears that lawmakers at the time weighed the increased cost of extending relief. And instead of choosing an …
Original document
Source: California Supreme Court