Case Brief - Michael M. v. Sonoma County Superior Court PDF

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It's a case brief, which is a required "reading notes" that we had to take before every class....

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POL 226, Dr. Harriger – Janice Park Michael M. v. Sonoma County Superior Court 450 U.S. 464 (1981) Facts: Legally Relevant Facts : Michael M., who is a 17-year-old male, was accused of violating California’s “statutory rape” law, which makes it unlawful to have a sex with a female who is under the age of 18 years, and is not a wife of a perpetrator. He said that such law is unconstitutional as it only accuses males and put blames on males only. Procedurally Relevant Facts : The Supreme Court of California held that the classification, when subjected to “strict scrutiny,” was justified by the state’s compelling interest to avoid the cost of il-legitimate teenage pregnancies, abortions, and teenage childbearing.

Issue(s): Whether California’s “statutory rape” law violates the Equal Protection Clause of the Fourteenth Amendment. Holding: The judgement of the California Supreme Court is affirmed. Reasoning: With numerous negative consequences that teenage pregnancy has – such as economic burdens and abortions – the Court declared that the prevention of illegitimate pregnancy legitimate interest of the state. Also, the Court declared that young men and young women are not similarly situated with respect to the problems and the risks of sexual intercourse, as only women can be pregnant, and they suffer disproportionately the profound physical, emotional, and psychological consequences of sexual activity. “Because virtually all of the significant harmful and inescapably identifiable consequences of teenage pregnancy fall on the young female, a legislature acts well within its authority when it elects to punish only the participant who, by nature, suffers few of the consequences of his conduct. It is hardly unreasonable for a legislature acting to protect minor females to exclude them from punishment. Moreover, the risk of pregnancy itself constitutes a substantial deterrence to young females. No similar natural sanctions deter males. A criminal sanction imposed solely on males thus serves to roughly ‘equalize’ the deterrents on the sexes…” “There remains only petitioner’s contention that the statue is unconstitutional as it is applied to him because he, like Sharon, was under 18 at the time of sexual intercourse. Petitioner argues that the statue is flawed because it presumes that as between two persons under 18, the male is the culpable aggressor. [The Court] find petitioner’s contentions unpersuasive … the statue does not rest on the assumption that males are generally the aggressors. It is instead an attempt by a legislature to prevent illegitimate teenage

POL 226, Dr. Harriger – Janice Park pregnancy by providing an additional deterrent for men. The age of the man is irrelevant since young men are as capable as older men of inflicting the harm sought to be prevented.” Dissenting Argument: Justice Brennan : “Common sense … suggests that a gender-neutral statutory rape law is potentially a greater deterrent of sexual activity than a gender-based law, for the simple reason that a gender-neutral law subjects both men and women to criminal sanctions and thus arguably has a deterrent effect on twice as many potential violators.” Justice Stevens : “The fact that a female confronts a greater risk of harm than a male is a reason for applying the prohibition to her – not a reason for granting her a license to use her own judgement on whether or not to assume the risk. Surely if we examine the problem from the point of view of society’s interest in preventing the risk-creating conduct from occurring at all, it is irrational to exempt 50% of the potential violators.”...