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Supreme Court of the United States - 450 U.S. 464
Tags: Constitutional Law, Sex Equality
The case involves a 17-year-old male charged with unlawful sexual intercourse with a female under 18 years old. The Supreme Court of California found that the law discriminates on the basis of sex and subjected the classification to "strict scrutiny." The court concluded that preventing teenage pregnancies is a compelling state interest and the gender classification was justified as a means of identifying the offender and victim. The judgment of the California Supreme Court was affirmed. The lower courts erred in denying the petitioner's request for relief. The appropriate standard of judicial review for substantive classification varies depending on the case. The legislature may provide for the special problems of women. The California Legislature criminalized illicit sexual intercourse with a minor female, but the exact reason for this desire is unclear.
The legal case involves the constitutionality of a California state law that punishes only males for having sexual intercourse with an underage female who is not his wife. The petitioner argues that this law violates his Fourteenth Amendment right to equal protection of the law. However, the Court upholds the constitutionality of the law, stating that gender-based classifications are not always unconstitutional and that the law is based on the clear difference that females can become pregnant as a result of sexual intercourse, while males cannot. The Court concludes that the Equal Protection Clause is not violated when men and women are not similarly situated in the area covered by the legislation in question.
Justice Blackmun agrees with the judgment and recognizes the significant consequences of teenage pregnancies for both the mother and child, as well as the state. He cites previous cases related to abortion and argues that the criminal sanctions imposed in the present case and H. L. v. Matheson are designed to address the same societal issue of regulating young people's sexual conduct. The opinion accepts the potential for teenage pregnancies to result in abortions and for the offspring of such pregnancies to be state-dependent. The author of the opinion disagrees with striking down California's statutory rape law, as it is a constitutional and reasonable attempt to address the issue of teenage pregnancy. The author distinguishes this state action from a state's refusal to recognize the consequences of forced or unwanted conception, which the author finds unconstitutional. The author believes that California's efforts to prevent teenage pregnancy are justified in preventing teenage pregnancy, despite acknowledging minors' privacy rights in intimate affairs related to procreation.
Justice Brennan dissents from the Court's decision, arguing that the gender-based classification in Cal. Penal Code Ann. §261.5 is unconstitutional as it does not have a sufficient relationship to the State's goal of preventing teenage pregnancies. The State has failed to provide evidence to support its assertion that its gender-based statutory classification substantially furthers an important governmental interest. The State's claim that a gender-neutral statutory rape law would be less effective in deterring sexual activity due to enforcement problems is flawed, as other jurisdictions have not experienced the enforcement problems that the State claims. The State has not demonstrated that such a law would be less effective in deterring minor females from engaging in sexual intercourse. A gender-neutral law could potentially be a greater deterrent of sexual activity than a gender-based law because it subjects both men and women to criminal sanctions. The State's failure to prove that a gender-neutral law would be a less effective deterrent than a gender-based law, along with its failure to prove that a gender-neutral law would be difficult to enforce, should have resulted in the invalidation of § 261.5.
The dissenting opinion argues that local customs should determine the sexual activity of unmarried teenagers rather than statutory laws. The author agrees with the majority that the illegal joint act incurs higher harm to females than males due to the possibility of pregnancy, but contests the assumption that the potential risk of getting pregnant discourages women from participating in the conduct. The author believes that susceptibility to harm is grounds for enforcing a law to a particular group, not excluding them. The author argues that the fact that females face a greater risk of harm than males is not a reason to exempt them from the prohibition of the risk-creating conduct. Instead, it is a reason to apply the prohibition to them. The author suggests that if pregnancy or some other special harm is suffered by one of the participants, it may constitute a legitimate mitigating factor in deciding appropriate punishment. The author argues that a general rule requiring different treatment of two participants in a joint act must be justified by a legislative judgment that one is more guilty than the other. The statute in question requires only one of two equally guilty wrongdoers to be convicted, which the author considers blatantly unfair.
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