People v. Chatman
| Decision Date | 01 February 2018 |
| Docket Number | S237374 |
| Citation | 410 P.3d 9,4 Cal.5th 277,228 Cal.Rptr.3d 379 |
| Parties | The PEOPLE, Plaintiff and Respondent, v. Jody CHATMAN, Defendant and Appellant. |
| Court | California Supreme Court |
David Reagan for Defendant and Appellant.
Kamala D. Harris and Xavier Becerra, Attorneys General, Gerald A. Engler, Chief Assistant Attorney General, Jeffrey M. Laurence, Assistant Attorney General, Seth K. Schalit, Kevin Kiley, Donna M. Provenzano, Laurence K. Sullivan and Catherine A. Rivlin, Deputy Attorneys General, for Plaintiff and Respondent.
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 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 appears that lawmakers at the time weighed the increased cost of extending relief. And instead of choosing an arbitrary means of limiting such access, legislators used subsequent incarceration as a means of determining which former probationers show the most promise for rehabilitation. If these justifications for the statute's treatment of former probationers do not necessarily reflect the ideal distribution of certificates of rehabilitation, neither can we conclude they are wholly irrational. What the framework enacted by the Legislature permits is for certain people to mitigate the effects of felony convictions in a world of limited resources. The basis for allocating those resources is sufficiently grounded in non-illusory distinctions between subsequently incarcerated former probationers and other classes of convicted felons to survive rational basis scrutiny under the equal protection clauses of the state and federal constitutions.
Jody Chatman was convicted of robbery in 2001. The trial judge sentenced him to a five- year term of felony probation with a 180-day term in jail. Two years later, Chatman was convicted of misdemeanor reckless driving with alcohol involved in violation of Vehicle Code section 23103, also called a "wet reckless." In 2006, the reckless driving conviction was dismissed under section 1203.4. In 2007, the robbery conviction was also dismissed under section 1203.4. Then, in 2008, Chatman was convicted of misdemeanor driving under the influence in violation of Vehicle Code section 23152, subdivision (b). He was sentenced to a three-year term of probation along with a 10-day term of imprisonment in county jail. In 2014, Chatman was offered a job that required a community care license from the Department of Social Services. Although Chatman's robbery conviction generally bars him from obtaining a community care license, the Department of Social Services "may grant an exemption" to this bar "if the employee or prospective employee has received a certificate of rehabilitation pursuant to ... Section 4852.01." ( Health & Saf. Code, § 1522, subd. (g)(1)(A)(ii).)2 Chatman filed a petition for a certificate of rehabilitation under section 4852.01 in October 2014. His petition acknowledged that he was "technically barred from a certificate of rehabilitation" but claimed that section 4852.01's unequal treatment of former probationers whose convictions had been dismissed under section 1203.4 was unconstitutional. The trial court denied the petition.
The Court of Appeal reversed that ruling. The court acknowledged that People v. Jones (1985) 176 Cal.App.3d 120, 221 Cal.Rptr. 382"was decided more than 30 years ago and addressed the identical question presented here." ( People v. Chatman (2016) 2 Cal.App.5th 561, 571, 206 Cal.Rptr.3d 322.) But it disagreed with Jones , which had upheld section 4852.01's eligibility criteria. ( Ibid . ) The Court of Appeal in Chatman's case then went on to observe that the ( Ibid. ) The court held that "the statutory scheme governing eligibility for certificates of rehabilitation denies Chatman his rights to equal protection." ( Id. at p. 572, 206 Cal.Rptr.3d 322.) It then remanded to the trial court "with directions to consider the merits of Chatman's petition for a certificate of rehabilitation." ( Id. at p. 573, 206 Cal.Rptr.3d 322.) We granted the Attorney General's petition for review.
Chatman claims it is unconstitutional for the Legislature to impose a disparate process for obtaining a certificate of rehabilitation through section 4852.01 on former probationers whose convictions were dismissed under section 1203.4. In the history and procedures associated with these certificates—along with the rules governing access to relief under section 1203.4 —we find the context for our analysis.
When the original certificate scheme was enacted, it was "an urgency measure" forged against the backdrop of World War II. ( People v. Ansell (2001) 25 Cal.4th 868, 874, 108 Cal.Rptr.2d 145, 24 P.3d 1174.) As demand for labor and military recruitment heightened, the Governor's office was deluged with pardon applications from ex-felons barred from serving in the military or working in defense-related industries. ( Id. at pp. 874-875, 108 Cal.Rptr.2d 145, 24 P.3d 1174.) The certificate of rehabilitation relieved pressure by creating a means for felons to apply for a pardon through which the merits of a particular application could be adjudicated, so that " 'the Governor [could], without any further investigation, issue a pardon to the person named therein.' " ( Id. at p. 876, 108 Cal.Rptr.2d 145, 24 P.3d 1174 ; see also § 4852.16 [].) Although an eventual pardon returns most of a convicted felon's rights (see Ansell , at p. 877, fn. 16, 108 Cal.Rptr.2d 145, 24 P.3d 1174 ), the certificate itself also provides relief from certain effects of a felony conviction, such as ineligibility from certain employment licenses ( id. at p. 877 & fn. 17, 108 Cal.Rptr.2d 145, 24 P.3d 1174 ; Health & Saf. Code, § 1522, subd. (g)(1)(A)(ii) []; Bus. & Prof. Code, § 480, subd. (b) [] ).
To obtain a certificate of rehabilitation and benefit from the relief it provides, petitioners must satisfy a number of conditions. An eligible felon may only file a petition for a certificate of rehabilitation after a specified "period of rehabilitation," which must last a minimum of five years from the petitioner's release from prison or placement on probation. (§ 4852.03, subds. (a), (b); § 4852.06.) During the period of rehabilitation, the petitioner must "live an honest and upright life, shall conduct himself or herself with sobriety and industry, shall exhibit a good moral character, and shall conform to and obey the...
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People v. Smith
...has the state adopted a classification affecting two or more groups that are similarly situated in an unequal manner? (People v. Chatman (2018) 4 Cal.5th 277, 289.) Second, if we deem the groups at issue similarly situated, does the challenged classification ultimately bear a rational relat......