rational relationship test (California) · Go Syfert
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rational relationship test in California

111 California opinions name it 4 courts 1973–2023 7 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (49)

CaseFollowedCited
Warden v. State Bar of Californiagreen
cal · 1999 · cited in 20 California opinions naming this issue, 2000–2023
2 sentences

2023(Cf. Warden v. State Bar (1999) 21 Cal.4th 628, 648, fn. 12 (Warden) [“under both the federal and state equal protection clauses, the rational relationship test remains a restrained, deferential standard”]; see also People v. Chatman (2018) 4 Cal.5th 277, 287, 288 ; Conservatorship of Eric B. (2022) 12 Cal.5th 1085 , 1113 [when urged to use California’s state equal protection clause “to articulate a unique set of state law specific principles, we’ve declined”] (conc. opn. of Kruger, J.).) Quinn’s challenge requires a return to basics.

2022The court noted that, “ ‘under the rational relationship test, the state may recognize that different categories or classes of persons within a larger classification may pose varying degrees of risk of harm, and properly may limit a regulation to those classes of persons as to whom the need for regulation is 4 thought to be more crucial or imperative,’ ” quoting Warden v. State Bar (1999) 21 Cal.4th 628, 644 (Warden).

1420
People v. Turnagegreen
cal · 2012 · cited in 9 California opinions naming this issue, 2012–2021
2 sentences

2021It is immaterial for rational basis review ‘whether or not’ any such speculation has ‘a foundation in the record.’ ” (People v. Turnage (2012) 55 Cal.4th 62, 74-75 (Turnage), quoted in Edwards, supra, 34 Cal.App.5th at p. 195 .) 37 To prevail on a claim that the disparate treatment violates the rational relationship test, a party must “ ‘negative every conceivable basis’ ” that might support the disparate treatment.

2021(Ibid.; People v. Turnage (2012) 55 Cal.4th 62, 75 (Turnage) [rejecting equal protection claim where the defendant did not negate every possible, plausible grounds for the classification].) The rational relationship test thus “sets a high bar before a law is deemed to lack even the minimal rationality necessary for it to survive constitutional scrutiny.” (Chatman, at p. 289.) Courts have long recognized that a state has a legitimate interest in imposing harsher punishment on recidivists and in enhancing public safety.

89
People v. Hofsheierred
cal · 2006 · cited in 23 California opinions naming this issue, 2006–2021
2 sentences

2016But most legislation is tested only to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (People v. Hofsheier (2006) 37 Cal.4th 1185, 1200 , overruled on other grounds in Johnson v. Department of Justice (2015) 60 Cal.4th 871 .) The analysis here is subject to the rational relationship test.

2015But most legislation is tested only 11 to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (Hofsheier, supra, 37 Cal.4th at p. 1200 .) Here, defendant contends “[t]he disparate treatment of sections 4573 and 4573.5 by section 1170 does not survive the rational relationship test.” “ ‘ “ ‘[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational bas

623
Williamson v. Lee Optical of Oklahoma, Inc.green
scotus · 1955 · cited in 6 California opinions naming this issue, 1995–2019
2 sentences

2019A plausible basis exists for the Legislature’s decision to provide relief only to accomplices convicted of murder under the natural and probable consequences doctrine A fundamental principle of rational-basis equal protection review, articulated by both the United States and California Supreme Courts, is “the propriety of a legislature’s taking reform ‘“one step at a time, addressing itself to the phase of the problem 32 which seems most acute to the legislative mind.”’” (Kasler v. Lockyer (2000) 23 Cal.4th 472, 488 ; accord, Warden v. State Bar, supra, 21 Cal.4th at p. 644 [“under the rationa

2019A plausible basis exists for the Legislature’s decision to provide relief only to accomplices convicted of murder under the natural and probable consequences doctrine A fundamental principle of rational-basis equal protection review, articulated by both the United States and California Supreme Courts, is “the propriety of a legislature’s taking reform ‘“one step at a time, addressing itself to the phase of the problem 32 which seems most acute to the legislative mind.”’” (Kasler v. Lockyer (2000) 23 Cal.4th 472, 488 ; accord, Warden v. State Bar, supra, 21 Cal.4th at p. 644 [“under the rationa

66
D'AMICO v. Board of Medical Examinersgreen
cal · 1974 · cited in 11 California opinions naming this issue, 1975–2015
2 sentences

1986Bib ’le v. Committee of Bar Examiners (1980) 26 Cal. 3d 548, 555 [ 162 Cal.Rptr. 426 , 606 P.2d 733 ]; D’Amico v. Board of Medical Examiners, supra, 11 Cal.3d at p. 17.) Thus, we are obliged to review the appointment of attorneys without compensation under the rational relationship test.

1983As an economic regulation, section 1582 need only satisfy the conventional equal protection standard of review that the challenged statute bear some “rational relationship” to a legitimate statute purpose. 4 (Westbrook *744 v. Mihaly (1970) 2 Cal.3d 765, 784 [ 87 Cal.Rptr. 839 , 471 P.2d 487 ], vacated on another point, 403 U.S. 915 [ 29 L.Ed.2d 692 , 91 S.Ct. 2224 ].) All presumptions favor the validity of the classification and the burden of demonstrating the invalidity of a classification under the rational relationship test rests upon the party challenging the statute (D’Amico v. Board of

511
Federal Communications Commission v. Beach Communications, Inc.green
scotus · 1993 · cited in 5 California opinions naming this issue, 1999–2011
2 sentences

2007(FCC v. Beach Communications, Inc. (1993) 508 U.S. 307, 313 [ 124 L.Ed.2d 211 , 113 S.Ct. 2096 ].) Appellants again cite the apparent inconsistency in the ordinance, which defines transience as 30 days or less but excludes from taxation persons who have paid 30 days’ rent in advance and may not terminate the occupancy “in less than thirty days.” As appellants read it, this means that a person would be exempt even if he or she terminates the occupancy on the thirtieth day, a situation that would otherwise make him or her transient. “[I]t is not the role of a court considering an equal protectio

2007(FCC v. Beach Communications, Inc. (1993) 508 U.S. 307, 313 [ 124 L.Ed.2d 211 , 113 S.Ct. 2096 ].) Appellants again cite the apparent inconsistency in the ordinance, which defines transience as 30 days or less but excludes from taxation persons who have paid 30 days’ rent in advance and may not terminate the occupancy “in less than thirty days.” As appellants read it, this means that a person would be exempt even if he or she terminates the occupancy on the thirtieth day, a situation that would otherwise make him or her transient. “[I]t is not the role of a court considering an equal protectio

45
American Bank & Trust Co. v. Community Hospitalgreen
cal · 1984 · cited in 4 California opinions naming this issue, 1997–2011
2 sentences

2011Past decisions by both this court and the United States Supreme Court “establish that, under the rational relationship test, the state may recognize that different categories or classes of persons within a larger classification may pose varying degrees of risk of harm, and properly may limit a regulation to those classes of persons as to whom the need for regulation is thought to be more crucial or imperative.” (Warden v. State Bar, supra, 21 Cal.4th at p. 644 , citing American Bank & Trust Co. v. Community Hospital (1984) 36 Cal.3d 359, 371 [ 204 Cal.Rptr. 671 , 683 P.2d 670 ], and Williamson

2011Past decisions by both this court and the United States Supreme Court “establish that, under the rational relationship test, the state may recognize that different categories or classes of persons within a larger classification may pose varying degrees of risk of harm, and properly may limit a regulation to those classes of persons as to whom the need for regulation is thought to be more crucial or imperative.” (Warden v. State Bar, supra, 21 Cal.4th at p. 644 , citing American Bank & Trust Co. v. Community Hospital (1984) 36 Cal.3d 359, 371 [ 204 Cal.Rptr. 671 , 683 P.2d 670 ], and Williamson

34
Newland v. Board of Governorsgreen
cal · 1977 · cited in 3 California opinions naming this issue, 2006–2015
2 sentences

2015But most legislation is tested only 11 to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (Hofsheier, supra, 37 Cal.4th at p. 1200 .) Here, defendant contends “[t]he disparate treatment of sections 4573 and 4573.5 by section 1170 does not survive the rational relationship test.” “ ‘ “ ‘[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational bas

2014But most legislation is tested only to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (Hofsheier, supra, 37 Cal.4th at p. 1200 .) Here, defendant contends “[t]he disparate treatment of sections 4573 and 4573.5 by section 1170 does not survive the rational relationship test.” “ ‘ “ ‘[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis

33
Hays v. Woodgreen
cal · 1979 · cited in 3 California opinions naming this issue, 1999–2010
2 sentences

2010“Past decisions . . . establish that, under the rational relationship test, the state may recognize that different categories or classes of persons within a larger classification may pose varying degrees of risk of harm, and properly may limit a regulation to those classes of persons as to whom the need for regulation is thought to be more crucial or imperative.” (Warden v. State Bar, supra, 21 Cal.4th at p. 644 .) It is also the case, however, that “the legislative body, when it chooses to address a particular area of concern in less than comprehensive fashion by merely ‘striking the evil whe

2000Suspect classifications, such as those based on race or that impact rights the court deems `fundamental,' warrant strict (read `fatal') scrutiny; other classifications warrant rational basis (read `anything goes') review. ( FCC v. Beach Communications, Inc., supra, 508 U.S. 307, 313-316 [ 113 S.Ct. 2096 , 124 L.Ed.2d 211 ].) As Justice Mosk so aptly put it, `[t]he vice of the binary theory ... is that it applies either a standard that is virtually always met (the rational relationship test) or one that is almost never satisfied (the strict scrutiny test). [Citation.] Once the test is selected,

33
Kasler v. Lockyergreen
cal · 2000 · cited in 9 California opinions naming this issue, 2000–2021
2 sentences

2021Under the rational relationship test, a statutory classification “ ‘ “must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification. [Citations.] Where there are ‘plausible reasons’ for [the classification] ‘our inquiry is at an end.’ ” ’ ” (Kasler v. Lockyer (2000) 23 Cal.4th 472, 481-482 , italics omitted.) “The underlying rationale for a statutory classification need not have been ‘ “ever actually articulated’ ’ by lawmakers, and it does not need to ‘ “be empirically substantiated.’ ” [Citat

2019A plausible basis exists for the Legislature’s decision to provide relief only to accomplices convicted of murder under the natural and probable consequences doctrine A fundamental principle of rational-basis equal protection review, articulated by both the United States and California Supreme Courts, is “the propriety of a legislature’s taking reform ‘“one step at a time, addressing itself to the phase of the problem 32 which seems most acute to the legislative mind.”’” (Kasler v. Lockyer (2000) 23 Cal.4th 472, 488 ; accord, Warden v. State Bar, supra, 21 Cal.4th at p. 644 [“under the rationa

29
Johnson v. Department of Justicegreen
cal · 2015 · cited in 4 California opinions naming this issue, 2015–2023
2 sentences

2022(Rubio v. Superior Court (1979) 24 Cal.3d 93, 102 (Rubio) [“jury duty is not a ‘fundamental right’ and any restriction thereof is to be judged by the rational relationship standard”]; Johnson, supra, 60 Cal.4th at p. 881 [equal protection claim regarding differing sex offender registration rules for different sex offenses “implicates no suspect class”]; Legg v. Department of Justice (2022) 81 Cal.App.5th 504 , 511 [“sex offender registration does not implicate a suspect class”].) Rational basis review “ ‘is the basic and conventional standard for reviewing economic and social welfare legislati

2022(Rubio v. Superior Court (1979) 24 Cal.3d 93, 102 (Rubio) [“jury duty is not a ‘fundamental right’ and any restriction thereof is to be judged by the rational relationship standard”]; Johnson, supra, 60 Cal.4th at p. 881 [equal protection claim regarding differing sex offender registration rules for different sex offenses “implicates no suspect class”]; Legg v. Department of Justice (2022) 81 Cal.App.5th 504 , 511 [“sex offender registration does not implicate a suspect class”].) Rational basis review “ ‘is the basic and conventional standard for reviewing economic and social welfare legislati

24
Nordlinger v. Hahngreen
scotus · 1992 · cited in 3 California opinions naming this issue, 2006–2015
2 sentences

2015But most legislation is tested only 11 to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (Hofsheier, supra, 37 Cal.4th at p. 1200 .) Here, defendant contends “[t]he disparate treatment of sections 4573 and 4573.5 by section 1170 does not survive the rational relationship test.” “ ‘ “ ‘[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational bas

2015But most legislation is tested only 11 to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (Hofsheier, supra, 37 Cal.4th at p. 1200 .) Here, defendant contends “[t]he disparate treatment of sections 4573 and 4573.5 by section 1170 does not survive the rational relationship test.” “ ‘ “ ‘[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational bas

23
Fein v. Permanente Medical Groupgreen
cal · 1985 · cited in 3 California opinions naming this issue, 1997–2015
2 sentences

2015But most legislation is tested only 11 to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (Hofsheier, supra, 37 Cal.4th at p. 1200 .) Here, defendant contends “[t]he disparate treatment of sections 4573 and 4573.5 by section 1170 does not survive the rational relationship test.” “ ‘ “ ‘[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational bas

2014But most legislation is tested only to determine if the challenged classification bears a rational relationship to a legitimate state purpose.” (Hofsheier, supra, 37 Cal.4th at p. 1200 .) Here, defendant contends “[t]he disparate treatment of sections 4573 and 4573.5 by section 1170 does not survive the rational relationship test.” “ ‘ “ ‘[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis

23
Brown v. Merlogreen
cal · 1973 · cited in 3 California opinions naming this issue, 1983–1985
2 sentences

1983(Brown v. Merlo (1973) 8 Cal.3d 855, 862, fn. 2 [ 106 Cal.Rptr. 388 , 506 P.2d 212 , 66 A.L.R.3d 505 ].) Thus, we apply “the familiar rational-relationship test, which is used to test the constitutionality of economic regulations.” (American Bank & Trust Co. v. Community Hospital (1983) 33 Cal.3d 674 , 686 [ 190 Cal.Rptr. 371 , 660 P.2d 829 ].) Code of Civil Procedure section 340.5 was amended to its present form in 1975 as part of the Medical Injury Compensation Reform Act (MICRA).

1983(Brown v. Merlo (1973) 8 Cal.3d 855, 862, fn. 2 [ 106 Cal.Rptr. 388 , 506 P.2d 212 , 66 A.L.R.3d 505 ].) Thus, we apply “the familiar rational-relationship test, which is used to test the constitutionality of economic regulations.” (American Bank & Trust Co. v. Community Hospital (1983) 33 Cal.3d 674 , 686 [ 190 Cal.Rptr. 371 , 660 P.2d 829 ].) Code of Civil Procedure section 340.5 was amended to its present form in 1975 as part of the Medical Injury Compensation Reform Act (MICRA).

23
Nordyke v. Kinggreen
ca9 · 2012 · cited in 2 California opinions naming this issue, 2014–2014
2 sentences

2014(Id. at p. 479.) The Kasler court said, “ ‘ “[i]n areas of social and economic policy, a statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification. [Citations.] Where there are ‘plausible reasons’ for [the classification] ‘our inquiry is at an end.’ ” [Citations.] Past decisions also establish that, under the rational relationship test, the state may recognize that different ca

2014(Kasler, at p. 479.) The Kasler *470 court said, “ ‘ “[i]n areas of social and economic policy, a statutory classification that neither proceeds along suspect lines nor infringes fimdamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state' of facts that could provide a rational basis for the classification. [Citations.] Where there are ‘plausible reasons’ for [the classification] ‘our inquiry is at an end.’ ” [Citations.] Past decisions also establish that, under the rational relationship test, the state may recognize that di

22
People v. Leunggreen
calctapp · 1992 · cited in 2 California opinions naming this issue, 2004–2005
2 sentences

2005(People v. Leung (1992) 5 Cal.App.4th 482, 496 [ 7 Cal.Rptr.2d 290 ].) By enacting Code of Civil Procedure section 223, the voters sought to prevent abuse of the jury selection process in criminal cases.

2005(People v. Leung (1992) 5 Cal.App.4th 482, 496 [ 7 Cal.Rptr.2d 290 ].) By enacting Code of Civil Procedure section 223, the voters sought to prevent abuse of the jury selection process in criminal cases.

22
Werner v. Southern California Associated Newpapersgreen
cal · 1950 · cited in 2 California opinions naming this issue, 1999–2000
22
United States Railroad Retirement Board v. Fritzgreen
scotus · 1981 · cited in 2 California opinions naming this issue, 1999–2000
22
Board of Supervisors v. Local Agency Formation Commissiongreen
cal · 1992 · cited in 2 California opinions naming this issue, 1994–1999
22
Vance v. Bradleygreen
scotus · 1979 · cited in 2 California opinions naming this issue, 1998–1999
22
Schad v. Borough of Mount Ephraimgreen
scotus · 1981 · cited in 2 California opinions naming this issue, 1985–1999
22
People v. Browngreen
cal · 2012 · cited in 3 California opinions naming this issue, 2013–2020
2 sentences

2020(See People v. Brown (2012) 54 Cal.4th 314, 325, 327-329 ; In re Stinnette (1979) 94 Cal.App.3d 800, 805, fn. 4, 806 .) Therefore, the rational relationship test applies.

2015Instead of addressing punishment for past criminal conduct, the statute addresses future conduct in a custodial setting by providing increased incentives for good behavior.” (People v. Brown (2012) 54 Cal.4th 314, 325 .) The rational relationship test therefore applies here, and it is met.

13
People v. Floydgreen
cal · 2003 · cited in 3 California opinions naming this issue, 2013–2016
2 sentences

2016(Floyd, supra, 31 Cal.4th at p. 191 ; People v. Cruz [(2012)] 207 Cal.App.4th [664,] 678–680.) Prisoners are not a suspect class.

2015(People v. Floyd (2003) 31 Cal.4th 179, 187-188, 191 ; People v. Cruz (2012) 207 Cal.App.4th 664, 678-680 .) Prisoners are not a suspect class.

13
Hernandez v. Department of Motor Vehiclesgreen
cal · 1981 · cited in 3 California opinions naming this issue, 1985–2001
2 sentences

2001Under this standard, "`"It is enough that there is an evil at hand for correction, and that it might be thought that the particular legislative measure was a rational way to correct it."'" ( Hernandez v. Department of Motor Vehicles (1981) 30 Cal.3d 70, 79 , 177 Cal.Rptr. 566 , 634 P.2d 917 , fn. omitted.) In enacting section 707(d), the people of this state desired to take a measured approach to serious and violent crime and gang activity committed by juveniles.

2001Under this standard, "`"It is enough that there is an evil at hand for correction, and that it might be thought that the particular legislative measure was a rational way to correct it."'" ( Hernandez v. Department of Motor Vehicles (1981) 30 Cal.3d 70, 79 , 177 Cal.Rptr. 566 , 634 P.2d 917 , fn. omitted.) In enacting section 707(d), the people of this state desired to take a measured approach to serious and violent crime and gang activity committed by juveniles.

13
People v. Chatmangreen
cal · 2018 · cited in 2 California opinions naming this issue, 2021–2023
2 sentences

2023(Cf. Warden v. State Bar (1999) 21 Cal.4th 628, 648, fn. 12 (Warden) [“under both the federal and state equal protection clauses, the rational relationship test remains a restrained, deferential standard”]; see also People v. Chatman (2018) 4 Cal.5th 277, 287, 288 ; Conservatorship of Eric B. (2022) 12 Cal.5th 1085 , 1113 [when urged to use California’s state equal protection clause “to articulate a unique set of state law specific principles, we’ve declined”] (conc. opn. of Kruger, J.).) Quinn’s challenge requires a return to basics.

2021Under the rational relationship test, a statutory classification “ ‘ “must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification. [Citations.] Where there are ‘plausible reasons’ for [the classification] ‘our inquiry is at an end.’ ” ’ ” (Kasler v. Lockyer (2000) 23 Cal.4th 472, 481-482 , italics omitted.) “The underlying rationale for a statutory classification need not have been ‘ “ever actually articulated’ ’ by lawmakers, and it does not need to ‘ “be empirically substantiated.’ ” [Citat

12
In Re Stinnettegreen
calctapp · 1979 · cited in 2 California opinions naming this issue, 2010–2020
2 sentences

2020(See People v. Brown (2012) 54 Cal.4th 314, 325, 327-329 ; In re Stinnette (1979) 94 Cal.App.3d 800, 805, fn. 4, 806 .) Therefore, the rational relationship test applies.

2010I, § 7.) "`The concept of the equal protection of the laws compels recognition of the proposition that persons similarly situated with respect to the legitimate purpose of the law receive like treatment.'" ( In re Gary W. (1971) 5 Cal.3d 296, 303 [ 96 Cal.Rptr. 1 , 486 P.2d 1201 ].) Where, as here, the statutory distinction at issue neither "touch[es] upon fundamental interests" nor is based on gender, there is no equal protection violation "if the challenged classification bears a rational relationship to a legitimate state purpose. [Citations.]" ( People v. Hofsheier (2006) 37 Cal.4th 1185,

12
People v. Cruzgreen
calctapp · 2012 · cited in 2 California opinions naming this issue, 2014–2015
2 sentences

2015(People v. Cruz, supra, at pp. 675-676, fn. 11 .) Under the rational relationship test, “equal protection of the law is denied only where there is no ‘rational relationship between the disparity of treatment and some legitimate governmental purpose.’ [Citation.]” (People v. Turnage (2012) 55 Cal.4th 62, 74 .) The discretionary public safety exception to second strike sentencing that is present in section 1170.126, is rationally related to a legitimate state interest.

2014(Rajanayagam, at p. 55; see Kennedy, at p. 397) “Where, as here, the statutory distinction at issue neither touches upon fundamental interests nor is based on gender, there is no equal protection violation if the challenged classification bears a rational relationship to a legitimate state purpose. ([People v. Hofsheier (2006) 37 Cal.4th 1185 ,] 1201; [People v.] Cruz, supra, 207 Cal.App.4th at pp. 677-679.) Under the rational relationship test, a statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal prot

12
People v. Boulericegreen
calctapp · 1992 · cited in 2 California opinions naming this issue, 2004–2005
2 sentences

2005(Boulerice, supra, 5 Cal.App.4th at p. 474.) [f] As the People observe, therefore, the statute’s distinction between criminal and civil voir dire is constitutional as long as it is rationally related to a legitimate state purpose under the rational relationship test, a test met here.

2004(Boulerice, supra, 5 Cal.App.4th at p. 474 .) As the People observe, therefore, the statute’s distinction between criminal and civil voir dire is constitutional as long as it is rationally related to a legitimate state purpose under the rational relationship test, a test met here.

12
People v. Bellgreen
calctapp · 1996 · cited in 2 California opinions naming this issue, 2002–2002
12
Central State Univ. v. American Assn. of Univ. Professors, Central State Univ. Chaptergreen
scotus · 1999 · cited in 2 California opinions naming this issue, 1999–2000
12
Fullerton Joint Union High School District v. State Board of Educationgreen
cal · 1982 · cited in 2 California opinions naming this issue, 1992–1994
12
Rubio v. Superior Courtgreen
cal · 1979 · cited in 1 California opinions naming this issue, 2022–2022
11
Cecelia Packing Corporation v. United States Department Of Agriculture/Agricultural Marketing Servicegreen
ca9 · 1993 · cited in 1 California opinions naming this issue, 2021–2021
11
People v. Coopergreen
calctapp · 1996 · cited in 1 California opinions naming this issue, 2021–2021
11
Heller v. Doe Ex Rel. Doegreen
scotus · 1993 · cited in 1 California opinions naming this issue, 2021–2021
11
People v. Kilborngreen
calctapp · 1996 · cited in 1 California opinions naming this issue, 2021–2021
11
Texas v. McCulloughgreen
scotus · 1986 · cited in 1 California opinions naming this issue, 2021–2021
11
People v. Superior Courtgreen
calctapp · 2014 · cited in 1 California opinions naming this issue, 2021–2021
11
The People v. Vallejogreen
calctapp · 2013 · cited in 1 California opinions naming this issue, 2020–2020
11
Bowen v. Owensgreen
scotus · 1986 · cited in 1 California opinions naming this issue, 2019–2019
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
People v. Dat Tan Nguyengreen
calctapp · 1997 · cited in 3 California opinions naming this issue, 2002–2014
2 sentences

2014(Id. at p. 1200.) Since the only difference between the two offenses was the nature of the sexual act, the court found persons convicted under the two statutes were “ ‘sufficiently similar to merit application of some level of scrutiny to determine whether distinctions between the two groups justify the unequal treatment.’ ” (Ibid., quoting People v. Nguyen (1997) 54 Cal.App.4th 705, 715 .) Because the case involved no classification subject to heightened scrutiny under established equal protection jurisprudence, the court held the rational relationship test applied.

2003It is this difference, however, “which is challenged as not justified by the purpose of [the statutes at issue].” (People v. Nguyen, supra, 54 Cal.App.4th at p. 715 .) “In our view, these two groups are sufficiently similar to merit application of some level of scrutiny to determine whether distinctions between the two groups justify the unequal treatment.” (Ibid.) “The next step in analyzing an equal protection challenge is a determination of the appropriate standard of review.” (People v. Nguyen, supra, 54 Cal.App.4th at p. 715 .) In reviewing an equal protection challenge, the courts genera

13

Also cited on this issue (30)

CaseCitedYears
People v. Rajanayagam green
calctapp · 2012
2 sentences

2014Although such an effort may have resulted in comparable groups obtaining different credit earning results, under the rational relationship test, the Legislature is permitted to engage in piecemeal approaches to statutory schemes addressing social ills and funding services to see what works and what does not.” (Kennedy, supra, 209 Cal.App.4th at p. 399 , fn. omitted.) In contrast, the court in People v. Rajanayagam (2012) 211 Cal.App.4th 42 (Rajanayagam), held the two affected groups were similarly situated.

2013Where, as here, the statutory distinction at issue neither touches upon fundamental interests nor is based on gender, there is no equal protection violation if the challenged classification bears a rational relationship to a legitimate state purpose. [Citations.] Under the rational relationship test, a statutory 2 classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification. [Citation].” (R

62013–2014
People v. Kennedy green
calctapp · 2012
2 sentences

2014Although such an effort may have resulted in comparable groups obtaining different credit earning results, under the rational relationship test, the Legislature is permitted to engage in piecemeal approaches to statutory schemes addressing social ills and funding services to see what works and what does not.” (Kennedy, supra, 209 Cal.App.4th at p. 399 , fn. omitted.) In contrast, the court in People v. Rajanayagam (2012) 211 Cal.App.4th 42 (Rajanayagam), held the two affected groups were similarly situated.

2013We see nothing irrational or implausible in a legislative conclusion that individuals should be punished in accordance with the sanctions and given the rewards (conduct credits) in effect at the time an offense was committed." (People v. Kennedy, supra, 209 Cal.App.4th at p. 399 .) Although the amendment to section 4019 may result in the two classifications obtaining different conduct credit earning results, under the rational relationship test, the Legislature is permitted to "experiment individually with various therapeutic programs related to criminal charges or convictions" (In re Huffman

52013–2014
People v. Lynch green
calctapp · 2012
2 sentences

2013We see nothing irrational or implausible in a legislative conclusion that individuals should be punished in accordance with the sanctions and given the rewards (conduct credits) in effect at the time an offense was committed." (People v. Kennedy, supra, 209 Cal.App.4th at p. 399 .) Although the amendment to section 4019 may result in the two classifications obtaining different conduct credit earning results, under the rational relationship test, the Legislature is permitted to "experiment individually with various therapeutic programs related to criminal charges or convictions" (In re Huffman

2013We see nothing irrational or implausible in a legislative conclusion that individuals should be punished in accordance with the sanctions and given the rewards (conduct credits) in effect at the time an offense was committed." (People v. Kennedy, supra, 209 Cal.App.4th at p. 399 .) Although the amendment to section 4019 may result in the two classifications obtaining different conduct credit totals, under the rational relationship test the Legislature is permitted to "experiment individually with various therapeutic programs related to 21 criminal charges or convictions" (In re Huffman (1986)

52013–2013
In Re Huffman green
cal · 1986
2 sentences

2013We see nothing irrational or implausible in a legislative conclusion that individuals should be punished in accordance with the sanctions and given the rewards (conduct credits) in effect at the time an offense was committed." (People v. Kennedy, supra, 209 Cal.App.4th at p. 399 .) Although the amendment to section 4019 may result in the two classifications obtaining different conduct credit earning results, under the rational relationship test, the Legislature is permitted to "experiment individually with various therapeutic programs related to criminal charges or convictions" (In re Huffman

2013We see nothing irrational or implausible in a legislative conclusion that individuals should be punished in accordance with the sanctions and given the rewards (conduct credits) in effect at the time an offense was committed." (People v. Kennedy, supra, 209 Cal.App.4th at p. 399 .) Although the amendment to section 4019 may result in the two classifications obtaining different conduct credit totals, under the rational relationship test the Legislature is permitted to "experiment individually with various therapeutic programs related to 21 criminal charges or convictions" (In re Huffman (1986)

52013–2013
People v. Yearwood green
calctapp · 2013
2 sentences

2014Such a “loophole,” the court reasoned, would be inconsistent with the public safety purpose of the Act. ( Yearwood, supra, at p. 176 .) Yearwood also rejected the argument that failing to apply the mandatory ameliorative benefits of Proposition 36 retroactively would violate the equal protection clause of the federal Constitution, noting that the rational relationship test is the appropriate test and concluding: “Prospective application of amended sections 667 and 1170.12 furthers legitimate interests and does not unfairly discriminate against [defendant].

2014(Yearwood, supra, 213 Cal.App.4th at p. 176 .) Although not raised specifically here, we note in passing that Yearwood also rejected the argument that failing to apply the mandatory ameliorative benefits of Proposition 36 retroactively would violate the equal protection clause of the federal Constitution, noting that the rational relationship test is the appropriate test, and concluding: “Prospective application of amended sections 667 and 1170.12 furthers legitimate interests and does not unfairly discriminate against appellant.

42014–2016
Waremart Foods v. United Food and Commercial Workers Union, Local 588 green
calctapp · 2001
2 sentences

2012The Court of Appeal acknowledged that, as to section 1138.1, it had reached a contrary result in Waremart/United Food, supra, 87 Cal.App.4th 145 , but it said it had there “applied the rational relationship test because the plaintiff made no argument and presented no authority to apply the strict scrutiny test.” This court granted the Union’s petition for review.

2012The Court of Appeal acknowledged that, as to section 1138.1, it had reached a contrary result in Waremart/United Food, supra, 87 Cal.App.4th 145 , but it said it had there ―applied the rational relationship test because the plaintiff made no argument and presented no authority to apply the strict scrutiny test.‖ This court granted the Union‘s petition for review.

22010–2012
Benelli v. City of New Orleans green
lactapp · 1985
21997–1997
California Gillnetters Ass'n v. Department of Fish & Game green
calctapp · 1995
21997–1997
Nellie Woods, as Personal Representative of the Estate of John N. Woods v. Holy Cross Hospital green
ca5 · 1979
21997–1997
City of Crowley Firemen v. City of Crowley green
la · 1973
21997–1997
Lochner v. New York red
scotus · 1905
12023–2023
Southern California Rapid Transit District v. Bolen green
cal · 1992
12021–2021
People v. Parker green
calctapp · 2006
12021–2021
People v. Smith green
calctapp · 2011
12021–2021
Ball v. James green
scotus · 1981
12021–2021
People v. Edwards green
calctapp5d · 2019
12021–2021
Blakely v. Washington green
scotus · 2004
12020–2020
Apprendi v. New Jersey green
scotus · 2000
12020–2020
Advanced Micro Devices, Inc. v. Intel Corp. green
cal · 1994
12020–2020
People v. Sumstine green
cal · 1984
12016–2016
In Re Jensen green
cal · 1978
12015–2015
Doe v. California Dept. of Justice green
calctapp · 2009
12015–2015
The People v. Super. Ct. green
calctapp · 2013
12015–2015
Chan v. Curran green
calctapp · 2015
12015–2015
People v. Buffington green
calctapp · 1999
12014–2014
People v. Castellanos green
cal · 1999
12014–2014
Nordyke v. King green
ca9 · 2011
12014–2014
People v. Moore green
calctapp · 1990
12013–2013
People v. Spears green
calctapp · 1995
12013–2013
Harper v. Virginia Board of Elections green
scotus · 1966
12010–2010

Statutes the citing opinions construe

CA § Cal. Civil Code § 3333.2 (5) CA § Cal. Penal Code § 187 (5) CA § Cal. Evidence Code § 352 (4) CA § Cal. Penal Code § 4019 (4) CA § Cal. Penal Code § 459 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 111 (1973–2023) WA 69 (1975–2021) PA 37 (1974–2019) TX 20 (1982–2025) FL 16 (1980–2023) CO 16 (1980–1999) GA 12 (1981–2014) NY 11 (1979–2006) IL 11 (1977–2015) WY 9 (1989–2026) LA 8 (1992–2009) NJ 8 (1974–2008) AL 7 (1984–2002) NE 7 (1996–2006) IA 7 (1980–2022) CT 6 (1975–2001) OK 6 (1982–2009) NC 5 (1985–2015) KS 5 (1982–2020) SC 5 (1978–2017) WV 5 (1980–2025) MA 5 (1993–2001) MT 5 (1989–2009) NM 5 (1994–2012) WI 4 (1979–2005) HI 4 (1993–2015) MI 4 (1983–1994) ND 3 (1986–1999) OH 3 (1994–2000) AK 3 (1985–1995) OR 3 (2006–2019) MO 3 (1978–1983) DE 2 (1977–1990) NH 2 (1987–1994) AZ 2 (1998–2002) ME 2 (1992–1997) RI 2 (1990–1993)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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