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Name: People v. Chatman
Case #: S237374
Court: CA Supreme Court
District CalSup
Opinion Date: 02/01/2018

Certificate of rehabilitation statute, which distinguishes between former state prisoners and former felony probationers with respect to eligibility, does not deny equal protection of the law. In 2001, Chatman pleaded guilty to robbery and was placed on probation. Two years later, he was convicted of an alcohol-related driving offense. He later had both convictions dismissed (Pen. Code, § 1203.4). In 2008 he was convicted of a misdemeanor and spent 10 days in jail. In order to obtain licensing for a job, Chatman sought a certificate of rehabilitation (Pen. Code, § 4852.01). The trial court denied relief because he was a former probationer who had been incarcerated after a section 1203.4 dismissal. The Court of Appeal concluded the statute’s eligibility distinction violated equal protection of the law. Review was granted. Held: Reversed. Felons who have successfully completed probation may petition for a certificate of rehabilitation, unless the probationer was incarcerated following the dismissal of his convictions under section 1203.4. (Pen. Code, § 4852.01, subd. (b).) In contrast, subdivision (a) of section 4852.01 allows a former felony prisoner to apply for a certificate of rehabilitation regardless of whether he remained free from incarceration after completing his prison term. The requirement of equal protection ensures that the government does not treat a group of people unequally without some justification. Assuming that former felony prisoners and former felony probationers who suffer subsequent incarceration are similarly situated for purposes of this law, the distinction need only have some legitimate government purpose as it is not based on a suspect class nor does it burden a fundamental right. The statutory scheme reflects a rational means of determining which former probationers show the most promise for rehabilitation. The disparity achieves the goal of decreasing the detrimental effects of felony convictions on those who achieve rehabilitation, while providing a method to manage demand for such certificates and thereby preserve government resources.

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