rational basis test in California

2023“An equal protection challenge to a statute that creates two classifications of accused or convicted defendants, without implicating a constitutional right, is subject to a rational-basis analysis.” (People v. Fitch (1997) 55 Cal.App.4th 172, 184 ; see also People v. Wilkinson (2004) 33 Cal.4th 821, 838 [a defendant “does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime receives”].) Other courts that have addressed this claim have applied the rational basis standard.

2023(People v. Wilkinson (2004) 33 Cal.4th 821, 837 .) In People v. Floyd (2003) 31 Cal.4th 179 , our Supreme Court applied the rational basis test in concluding that equal protection did not require Proposition 36 (the Substance Abuse and Crime Prevention Act of 2000 (Proposition 36)) to be applied retroactively to convictions not yet final.

2025(People v. Chatman (2018) 4 Cal.5th 277, 289 .) Under the rational basis test, “the legislation survives constitutional scrutiny as long as there is ‘ “any reasonably conceivable state of facts that could provide a rational basis for the classification.” ’ ” (People v. Turnage (2012) 55 Cal.4th 62, 74 .) “[A] court may engage in ‘ “rational speculation” ’ as to the justifications for the legislative choice. [Citation.] It is immaterial for rational basis review ‘whether or not’ any such speculation has “a foundation in the record.” (Id. at p. 75.) “Nor does the logic behind a potential justifi

2025(People v. Chatman (2018) 4 Cal.5th 277, 289 .) Under the rational basis test, “the legislation survives constitutional scrutiny as long as there is ‘ “any reasonably conceivable state of facts that could provide a rational basis for the classification.” ’ ” (People v. Turnage (2012) 55 Cal.4th 62, 74 .) “[A] court may engage in ‘ “rational speculation” ’ as to the justifications for the legislative choice. [Citation.] It is immaterial for rational basis review ‘whether or not’ any such speculation has “a foundation in the record.” (Id. at p. 75.) “Nor does the logic behind a potential justifi

2024(Kasler v. Lockyer (2000) 23 Cal.4th 472, 487 .) Our task is limited to determining whether Hardin has shown that the Legislature’s decision to expand youth offender parole hearings to most young adult offenders, while excluding Hardin and others similarly situated, violates equal protection under a rational basis standard.

2014In Kasler, our high court applied the rational basis test and rejected an equal protection challenge to the ban on specified weapons in the Assault Weapons Control Act 21 (former § 12275 et seq.). ( Kasler, supra, 23 Cal.4th at pp. 481-482.) The plaintiff argued the Act violated equal protection because it failed to include certain weapons identical to, or indistinguishable from, the listed assault weapons, and therefore treated persons who owned the listed weapons differently from persons who owned indistinguishable unlisted weapons.

1993(Nordlinger v. Hahn, supra,_ U.S. at p._[120 L.Ed.2d at pp. 17-18, 112 S.Ct. at p. 2336 ]; Coleman v. Department of Personnel Administration (1991) 52 Cal.3d 1102, 1125 [ 278 Cal.Rptr. 346 , 805 P.2d 300 ]; Fein v. Permanente Medical Group (1985) 38 Cal.3d 137, 163-164 [ 211 Cal.Rptr. 368 , 695 P.2d 665 ]; Cooper v. Bray (1978) 21 Cal.3d 841, 847-848 [ 148 Cal.Rptr. 148 , 582 P.2d 604 ].) 36 We agree. *1081 “When social or economic regulations are involved, the rational-basis test applies.

1993(Nordlinger v. Hahn, supra,_ U.S. at p._[120 L.Ed.2d at pp. 17-18, 112 S.Ct. at p. 2336 ]; Coleman v. Department of Personnel Administration (1991) 52 Cal.3d 1102, 1125 [ 278 Cal.Rptr. 346 , 805 P.2d 300 ]; Fein v. Permanente Medical Group (1985) 38 Cal.3d 137, 163-164 [ 211 Cal.Rptr. 368 , 695 P.2d 665 ]; Cooper v. Bray (1978) 21 Cal.3d 841, 847-848 [ 148 Cal.Rptr. 148 , 582 P.2d 604 ].) 36 We agree. *1081 “When social or economic regulations are involved, the rational-basis test applies.

2025Political Practices Com. v. Superior Court (1979) 25 Cal.3d 33, 47 ; see also Gould v. Grubb (1975) 14 Cal.3d 661, 670 (Gould); Butt v. State of California (1992) 4 Cal.4th 668 , 685–686.) Furthermore, within this specific context, we have emphasized that, despite the liberty interests involved, not “ ‘every detail of every civil commitment program is subject to strict scrutiny.’ ” (McKee, supra, 47 Cal.4th at p. 1210, fn. 13 .) Hardin explained that the burden of persuasion under a rational basis analysis is on the challenger: “The underlying rationale for a statutory classification need not

2023(Legg, at p. 511, citing People v. McKee (2010) 47 Cal.4th 1172, 1211, fn. 14 .) Under the rational basis analysis, courts first determine “whether the state adopted a classification affecting two or more groups that are similarly situated in an unequal manner.” (Chatman, supra, 4 Cal.5th at p. 289 .) If the court determines that the groups are “similarly situated in all material respects,” a disparity in treatment is constitutionally permissible if it “bears a rational relationship to a legitimate state purpose.” (Ibid.) Legg found both that: (1) section 288(c)(1) defendants are not similarly

2019(FCC v. Beach Communications, Inc. 10. (1993) 508 U.S. 307, 313 ; People v. Turnage (2012) 55 Cal.4th 62, 74 .) In Chatman, our Supreme Court provided an overview of the rational basis test, stating it “sets a high bar before a law is deemed to lack even the minimal rationality necessary for it to survive constitutional scrutiny.

2017"The crux of the constitutional promise of equal protection is that persons similarly situated shall be treated equally by the laws. [Citation.] However, neither clause [of the United States or California Constitutions] prohibits legislative bodies from making classifications; they simply require that laws or other governmental regulations be justified by sufficient reasons." ( In re Evans (1996) 49 Cal.App.4th 1263 , 1270, 57 Cal.Rptr.2d 314 .) Because a criminal defendant " 'does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime recei

2025(People v. Chatman (2018) 4 Cal.5th 277, 289 .) Under the rational basis test, “the legislation survives constitutional scrutiny as long as there is ‘ “any reasonably conceivable state of facts that could provide a rational basis for the classification.” ’ ” (People v. Turnage (2012) 55 Cal.4th 62, 74 .) “[A] court may engage in ‘ “rational speculation” ’ as to the justifications for the legislative choice. [Citation.] It is immaterial for rational basis review ‘whether or not’ any such speculation has “a foundation in the record.” (Id. at p. 75.) “Nor does the logic behind a potential justifi

2025(People v. Chatman (2018) 4 Cal.5th 277, 289 .) Under the rational basis test, “the legislation survives constitutional scrutiny as long as there is ‘ “any reasonably conceivable state of facts that could provide a rational basis for the classification.” ’ ” (People v. Turnage (2012) 55 Cal.4th 62, 74 .) “[A] court may engage in ‘ “rational speculation” ’ as to the justifications for the legislative choice. [Citation.] It is immaterial for rational basis review ‘whether or not’ any such speculation has “a foundation in the record.” (Id. at p. 75.) “Nor does the logic behind a potential justifi

2025Thus, the rational basis test governs our consideration of Getzels’s equal protection claim, which concerns the regulation of professional conduct. 6 (Hardin, supra, 15 Cal.5th at p. 847; Warden, supra, 21 Cal.4th at pp. 642–643.) We must therefore determine whether rule 2.30’s classification bears a rational relationship to a legitimate state purpose. scrutiny review because rule 2.30 violates the Contract Clause of the federal Constitution.

2025Thus, the rational basis test governs our consideration of Getzels’s equal protection claim, which concerns the regulation of professional conduct. 6 (Hardin, supra, 15 Cal.5th at p. 847; Warden, supra, 21 Cal.4th at pp. 642–643.) We must therefore determine whether rule 2.30’s classification bears a rational relationship to a legitimate state purpose. scrutiny review because rule 2.30 violates the Contract Clause of the federal Constitution.

2009(Newland, supra, 19 Cal.3d at p. 711 .) “Some decisions require that the classification ‘ “bear some rational relationship to a conceivable legitimate state purpose” ’ [citation]; others, that the classification must rest upon ‘some ground of difference having a fair and substantial relation to the object of the legislation’ . . . .” (Ibid.) At bottom, however, “[a]ll of the formulas require the court to conduct ‘a serious and genuine judicial inquiry into the correspondence between the classification and the legislative goals’ . . . .” (Ibid.) Accordingly, application of the rational basis te

1994The inquiry under the rational basis test is whether the policy bears “some rational relationship to a conceivable legitimate state purpose.” (Newland v. Board of Governors (1977) 19 Cal.3d 705, 711 [ 139 Cal.Rptr. 620 , 566 P.2d 254 ]; Rittenband v. Cory, supra, 159 Cal.App.3d at p. 417 .) The burden is on the party challenging the constitutionality of the policy to show that it bears no rational relationship to a legitimate governmental purpose.

1996(See D’Amico v. Board of Medical Examiners (1974) 11 Cal.3d 1, 16-17 [ 112 Cal.Rptr. 786 , 520 P.2d 10 ] [legislation].) The rational basis test applies to a regulation that differentiates or discriminates between classes of persons.

1996(See D’Amico v. Board of Medical Examiners (1974) 11 Cal.3d 1, 16-17 [ 112 Cal.Rptr. 786 , 520 P.2d 10 ] [legislation].) The rational basis test applies to a regulation that differentiates or discriminates between classes of persons.

2018We disagree. *428 Under the rational basis test, in an equal protection claim, the challenged classification need only further a legitimate state interest. ( City of Cleburne v. Cleburne Living Ctr. (1985) 473 U.S. 432 , 439-441, 105 S.Ct. 3249 , 87 L.Ed.2d 313 (plur. opn. of White, J.).) "In ordinary equal protection cases not involving suspect classifications or the alleged infringement of a fundamental interest, the classification is upheld if it bears a rational relationship to a legitimate state purpose." ( Weber v. City Council (1973) 9 Cal.3d 950 , 958-959, 109 Cal.Rptr. 553 , 513 P.2d

2018We disagree. *428 Under the rational basis test, in an equal protection claim, the challenged classification need only further a legitimate state interest. ( City of Cleburne v. Cleburne Living Ctr. (1985) 473 U.S. 432 , 439-441, 105 S.Ct. 3249 , 87 L.Ed.2d 313 (plur. opn. of White, J.).) "In ordinary equal protection cases not involving suspect classifications or the alleged infringement of a fundamental interest, the classification is upheld if it bears a rational relationship to a legitimate state purpose." ( Weber v. City Council (1973) 9 Cal.3d 950 , 958-959, 109 Cal.Rptr. 553 , 513 P.2d

2002"We believe that there is a qualitative difference, however, between the initial interest one has in retaining his [or her] liberty prior to sentencing and the interest one has in whether or not an enhancement applies." ( People v. Hernandez (1979) 100 Cal.App.3d 637, 644, fn. 2 , 160 Cal.Rptr. 607 .) Hernandez concluded that the rational basis test applied to a legislative distinction between prior in-state and out-of-state convictions as sentence enhancements.

2002"We believe that there is a qualitative difference, however, between the initial interest one has in retaining his [or her] liberty prior to sentencing and the interest one has in whether or not an enhancement applies." ( People v. Hernandez (1979) 100 Cal.App.3d 637, 644, fn. 2 , 160 Cal.Rptr. 607 .) Hernandez concluded that the rational basis test applied to a legislative distinction between prior in-state and out-of-state convictions as sentence enhancements.

1988We agree with appellant that the “rational basis” test is the appropriate standard to apply in evaluating the challenged legislative classification. 3 (See, e.g., Newland v. Board of Governors (1977) 19 Cal.3d 705, 711 [ 139 Cal.Rptr. 620 , 566 P.2d 254 ] [issuance of teaching credential]; D’Amico v. Board of Medical Examiners, supra, 11 Cal.3d at pp. 16-18 [issuance of medical license]; Reece v. Alcoholic Bev. etc. Appeals Bd., supra, 64 Cal.App.3d at pp. 679-681 [issuance of license to sell alcohol].) In discussing an analogous issue, this court aptly observed: “As described by the Californi

1988We agree with appellant that the “rational basis” test is the appropriate standard to apply in evaluating the challenged legislative classification. 3 (See, e.g., Newland v. Board of Governors (1977) 19 Cal.3d 705, 711 [ 139 Cal.Rptr. 620 , 566 P.2d 254 ] [issuance of teaching credential]; D’Amico v. Board of Medical Examiners, supra, 11 Cal.3d at pp. 16-18 [issuance of medical license]; Reece v. Alcoholic Bev. etc. Appeals Bd., supra, 64 Cal.App.3d at pp. 679-681 [issuance of license to sell alcohol].) In discussing an analogous issue, this court aptly observed: “As described by the Californi

2025“Under the rational basis test, the question is whether the Legislature’s differing treatment of similarly situated groups bears a fair relationship to a legitimate public purpose.” (Delacy, supra, 192 Cal.App.4th at p. 1496 .) “A statute is presumed constitutional [citation] and ‘[t]he burden is on the one attacking the legislative arrangement to negative every conceivable basis 14 which might support it[ ]’ [citation], whether or not the basis has a foundation in the record.” (Heller v. Doe (1993) 509 U.S. 312 , 320–321.) “In other words, the legislation survives constitutional scrutiny as l

2014Moreover, under the rational-basis test, “a 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.]” ( Heller, supra, 509 U.S. at p. 320 [ 113 S.Ct. 2637 ].) The legislative choice of making an inmate’s participation in sodomy, regardless of consent, a separate crime is rationally related to the legitimate state purpose of maintaining institutional safety and order.

2025(People v. Chatman (2018) 4 Cal.5th 277, 289 .) Under the rational basis test, “the legislation survives constitutional scrutiny as long as there is ‘ “any reasonably conceivable state of facts that could provide a rational basis for the classification.” ’ ” (People v. Turnage (2012) 55 Cal.4th 62, 74 .) “[A] court may engage in ‘ “rational speculation” ’ as to the justifications for the legislative choice. [Citation.] It is immaterial for rational basis review ‘whether or not’ any such speculation has “a foundation in the record.” (Id. at p. 75.) “Nor does the logic behind a potential justifi

2025(People v. Chatman (2018) 4 Cal.5th 277, 289 .) Under the rational basis test, “the legislation survives constitutional scrutiny as long as there is ‘ “any reasonably conceivable state of facts that could provide a rational basis for the classification.” ’ ” (People v. Turnage (2012) 55 Cal.4th 62, 74 .) “[A] court may engage in ‘ “rational speculation” ’ as to the justifications for the legislative choice. [Citation.] It is immaterial for rational basis review ‘whether or not’ any such speculation has “a foundation in the record.” (Id. at p. 75.) “Nor does the logic behind a potential justifi

2024(Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 837, 858 .) So “long as a plausible reason exists for the classification, our inquiry under the rational basis test comes to an end.” (Chorn v. Workers’ Comp.

2023“The rational basis test is extremely deferential and does not allow inquiry into the wisdom of government action.” (Las Lomas, supra, 177 Cal.App.4th at p. 858 .) Under this test, “courts must presume the constitutionality of government action if it is plausible that there were legitimate reasons for the action.

2026True, in Olivas, the California Supreme Court applied strict scrutiny review to a defendant’s equal protection challenge to a statute that permitted the trial court to sentence certain misdemeanants between the ages of 16 and 21 to the California Youth Authority for a longer term than could have been imposed for the same 4 In his reply brief, West mischaracterizes Alvarez as finding that strict scrutiny applies to firearm enhancements, but Alvarez expressly held that “the rational basis standard applies.” (Alvarez, supra, 88 Cal.App.4th at p. 1116 .) 9 offense in jail.

2016“A defendant ‘ “does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime receives.” (People v. Flores (1986) 178 Cal.App.3d 74 , 88 . . . ; see People v. Alvarez (2001) 88 Cal.App.4th 1110 , 1116 . . . [finding the rational basis test applicable to equal protection challenge involving “an alleged sentencing disparity”].)’ ” (Acosta, supra, 242 Cal.App.4th at p. 527 .) Accordingly, the “rational basis” standard applies to defendant’s asserted constitutional claim.

2019In applying the rational basis test, “neither the existence of two identical criminal statutes prescribing different levels of punishments, nor the exercise of a prosecutor’s discretion in charging under one such statute and not the other, violates equal protection principles.” (People v. Wilkinson, supra, 33 Cal.4th at pp. 838―841 [statutory scheme allowing battery on a custodial officer without injury to be punished more severely than battery on a custodial officer with injury did not violate equal protection principles]; People v. Romo (1975) 14 Cal.3d 189 , 196―197 [rejecting equal protect

2016“A defendant ‘ “does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime receives.” (People v. Flores (1986) 178 Cal.App.3d 74 , 88 . . . ; see People v. Alvarez (2001) 88 Cal.App.4th 1110 , 1116 . . . [finding the rational basis test applicable to equal protection challenge involving “an alleged sentencing disparity”].)’ ” (Acosta, supra, 242 Cal.App.4th at p. 527 .) Accordingly, the “rational basis” standard applies to defendant’s asserted constitutional claim.

2016(Ibid.) When applying the rational basis test, “ ‘we must accept any gross generalizations and rough accommodations that the Legislature seems to have made.’ [Citation.] ‘A classification is not arbitrary or irrational simply because there is an “imperfect fit between means and ends,” ’ [citation], or ‘because it may be “to some extent both underinclusive and overinclusive.” ’ [Citation.]” ( Johnson, supra, 60 Cal.4th at p. 887 .) “At bottom, the Legislature is afforded considerable latitude in defining and setting the consequences of criminal offenses.” (Ibid.) The Johnson court employed this

2016(Ibid.) When applying the rational basis test, “ ‘we must accept any gross generalizations and rough accommodations that the Legislature seems to have made.’ [Citation.] ‘A classification is not arbitrary or irrational simply because there is an “imperfect fit between means and ends,” ’ [citation], or ‘because it may be “to some extent both underinclusive and overinclusive.” ’ [Citation.]” ( Johnson, supra, 60 Cal.4th at p. 887 .) “At bottom, the Legislature is afforded considerable latitude in defining and setting the consequences of criminal offenses.” (Ibid.) The Johnson court employed this

2013(See People v. Applin (1995) 40 Cal.App.4th 404 , 409 … & cases cited.)‖ (Id. at p. 676, fn. omitted.) Thus, as appellant acknowledges, ―courts have reached different conclusions about which test applies to incongruities resulting from statutes involving time credits or other elements of criminal sentences.‖ For example, in People v. Saffell (1979) 25 Cal.3d 223 , this state‘s high court applied the compelling state interest test to a statutory scheme that precluded persons committed to state hospitals for treatment as mentally disordered sex offenders from earning custody credits that were av

2002Prior to Olivas , the California Supreme Court applied the rational basis standard in In re Kapperman (1974) 11 Cal.3d 542 , 114 Cal.Rptr. 97 , 522 P.2d 657 to a new statute prospectively awarding presentence custody credit. ( Id. at p. 545, 114 Cal.Rptr. 97 , 522 P.2d 657 .) The court stated that the equal protection clauses of the federal and state constitution "prohibit the state from arbitrarily discriminating among persons subject to its jurisdiction, and require that classifications between those to whom the state accords and withholds substantial benefits must be reasonably related to a

2018We disagree. *428 Under the rational basis test, in an equal protection claim, the challenged classification need only further a legitimate state interest. ( City of Cleburne v. Cleburne Living Ctr. (1985) 473 U.S. 432 , 439-441, 105 S.Ct. 3249 , 87 L.Ed.2d 313 (plur. opn. of White, J.).) "In ordinary equal protection cases not involving suspect classifications or the alleged infringement of a fundamental interest, the classification is upheld if it bears a rational relationship to a legitimate state purpose." ( Weber v. City Council (1973) 9 Cal.3d 950 , 958-959, 109 Cal.Rptr. 553 , 513 P.2d

2018We disagree. *428 Under the rational basis test, in an equal protection claim, the challenged classification need only further a legitimate state interest. ( City of Cleburne v. Cleburne Living Ctr. (1985) 473 U.S. 432 , 439-441, 105 S.Ct. 3249 , 87 L.Ed.2d 313 (plur. opn. of White, J.).) "In ordinary equal protection cases not involving suspect classifications or the alleged infringement of a fundamental interest, the classification is upheld if it bears a rational relationship to a legitimate state purpose." ( Weber v. City Council (1973) 9 Cal.3d 950 , 958-959, 109 Cal.Rptr. 553 , 513 P.2d

2016Oregon contends the liberty interest at stake in avoiding a lengthy sentence enhancement requires review under the strict scrutiny standard, but a defendant “‘does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime receives.’” (People v. Wilkinson (2004) 33 Cal.4th 821, 838 (Wilkinson).) Thus, the Legislature “‘is not prohibited by the equal protection clause from striking the evil where it is felt the most.’” (Hernandez, at p. 482, fn. omitted.) Citing People v. Olivas (1976) 17 Cal.3d 236 (Olivas), Oregon argues that we should not adop

2016Oregon contends the liberty interest at stake in avoiding a lengthy sentence enhancement requires review under the strict scrutiny standard, but a defendant “‘does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime receives.’” (People v. Wilkinson (2004) 33 Cal.4th 821, 838 (Wilkinson).) Thus, the Legislature “‘is not prohibited by the equal protection clause from striking the evil where it is felt the most.’” (Hernandez, at p. 482, fn. omitted.) Citing People v. Olivas (1976) 17 Cal.3d 236 (Olivas), Oregon argues that we should not adop

1993Thus, the voting residents of the area to be detached have a lesser interest in the operation of the District than those who reside in the Cities’ boundaries. *270 The recent case of Board of Supervisors v. Local Agency Formation Com. (1992) 3 Cal.4th 903 [ 13 Cal.Rptr.2d 245 , 838 P.2d 1198 ], supports the trial court’s employment of the rational basis analysis.

1993Thus, the voting residents of the area to be detached have a lesser interest in the operation of the District than those who reside in the Cities’ boundaries. *270 The recent case of Board of Supervisors v. Local Agency Formation Com. (1992) 3 Cal.4th 903 [ 13 Cal.Rptr.2d 245 , 838 P.2d 1198 ], supports the trial court’s employment of the rational basis analysis.

2017"The crux of the constitutional promise of equal protection is that persons similarly situated shall be treated equally by the laws. [Citation.] However, neither clause [of the United States or California Constitutions] prohibits legislative bodies from making classifications; they simply require that laws or other governmental regulations be justified by sufficient reasons." ( In re Evans (1996) 49 Cal.App.4th 1263 , 1270, 57 Cal.Rptr.2d 314 .) Because a criminal defendant " 'does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime recei

2017"The crux of the constitutional promise of equal protection is that persons similarly situated shall be treated equally by the laws. [Citation.] However, neither clause [of the United States or California Constitutions] prohibits legislative bodies from making classifications; they simply require that laws or other governmental regulations be justified by sufficient reasons." ( In re Evans (1996) 49 Cal.App.4th 1263 , 1270, 57 Cal.Rptr.2d 314 .) Because a criminal defendant " 'does not have a fundamental interest in a specific term of imprisonment or in the designation a particular crime recei

2013I, § 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.” ‟ [Citation.]” (Cooley v. Superior Court (2002) 29 Cal.4th 228, 253 .) Since the amendments to section 4019 do not involve a “ „ “ „suspect classification‟ ” ‟ ” or a “ „ “ „fundamental interest,‟ ” ‟ ” courts apply the rational basis test to determine whether the “distinction drawn by the challenged statute bears some rational relationship to a conceivable legitimate state purpose.” (In r

2013Sess., 2011-2012, ch. 12, § 35.) 30 [Citation.]” (Cooley v. Superior Court (2002) 29 Cal.4th 228, 253 .) Since the amendments to section 4019 do not involve a “ ‘ “ ‘suspect classification’ ” ’ ” or a “ ‘ “ ‘fundamental interest,’ ” ’ ” courts apply the rational basis test to determine whether the “distinction drawn by the challenged statute bears some rational relationship to a conceivable legitimate state purpose.” (In re Stinnette (1979) 94 Cal.App.3d 800, 805 .) Defendant maintains that he is similarly situated to a defendant whose crime was committed after October 1, 2011, and whose custo

2023(E.g., Santa Monica Beach, Ltd. v. Superior Ct. (1999) 19 Cal.4th 952, 970 [citing Skrupa]; Briggs v. Brown (2017) 3 Cal.5th 808, 828 [same].) Unless a suspect classification or some other basis triggers heightened scrutiny, modern equal protection analysis applies the rational basis test: “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.” (Williamson, supra, 348 U.S. at p. 488 .) “[A] statutory classification that neither proceeds along suspect lines nor infringes fundamental const

2002Inasmuch as the parties agree that the relevant effective date lies somewhere between 1982 and 1987, the purpose of the majority's discussion of usage rates between 1988 and 1991 (see maj. opn., ante, 117 Cal.Rptr.2d at pp. 278, 281, 41 P.3d at pp. 94-95, 97) is lost on me. [6] Justice Chin cogently explained the meaning of Dolan's footnote 8 in his dissenting opinion in Santa Monica Beach, supra, 19 Cal.4th at pages 1020 through 1021, 81 Cal. Rptr.2d 93 , 968 P.2d 993 . [7] The City misperceives the applicable standard to be "akin to the rational basis test." [8] The Court of Appeal found tha