In People v. Chatman, the Supreme Court today rejects an equal protection attack on a statutory scheme that treats former probationers differently from former prisoners. All former prisoners have the possibility of obtaining a certificate of rehabilitation, which can remove certain employment prohibitions. Ineligible are those who have successfully both completed probation and had their convictions dismissed, but who have been incarcerated again.
The Court of Appeal had struck down the law in a published opinion, concluding it saw “no rationale to deny certificate eligibility only to those who have served sentences of probation.” But the Supreme Court’s unanimous opinion by Justice Mariano-Florentino Cuéllar does find a rational rationale for the distinction: money. Stating that “[p]reserving the government’s financial integrity and resources is a legitimate state interest,” and speaking of rehabilitation certificates and the process for adjudicating petitions for them, the court says, “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.” The statutory scheme is “minimally rational enough,” the court concludes.
The court reverses the First District, Division One, Court of Appeal.
