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Michael M. v. Superior Court

Citation. 450 U.S. 464, 101 S.Ct. 1200, 67 L.Ed.2d 437 (1981).

Brief Fact Summary.

Plaintiff was charged with statutory rape in California and challenged the statute, arguing it was unconstitutional because it discriminated against men.

Synopsis of Rule of Law.

Sex-based classifications are constitutionally permissible if they bear a substantial relationship to an important government interest.

Facts.

Plaintiff was charged with statutory rape under a California statutory rape law. The law, however, only criminalized male behavior, not female. Because of the disparity in treatment between males and females, the Plaintiff challenged his conviction under the Equal Protection Clause of the 14th Amendment.

Issue.

Whether the California law violates the Equal Protection Clause of the 14th Amendment.

Held.

No. The California law does not violate the Equal Protection Clause of the 14th Amendment.

Dissent.

Justice Brennan

The Court is placing too much emphasis on the desirability of achieving the state’s asserted statutory goal and not enough emphasis on the fundamental question of whether the sex-based discrimination is substantially related to the achievement of the goal. Here, the state has not met its burden and the statute should be found to violate the Equal Protection Clause.

Justice Stevens

Even if there actually is some speculative basis for treating equally guilty males and females differently, any such speculative justification would be outweighed by the paramount interest in evenhanded enforcement of the law.

Concurrence.

Justice Blackmun

It is gratifying the plurality recognizes the the social, medical, and economic consequences of teenage pregnancy for both the mother and the child despite not recognizing them in the abortion context.

This case is like Craig v. Boren and Reed v. Reed and should be decided similarly.

Discussion.

Such a statute is sufficiently related to the state’s objectives and passes constitutional muster. Virtually all other significant, harmful and inescapably identifiable consequences of teenage pregnancy fall on the young female. A legislature is well within its authority to punish only the participate (the male) who, by nature, suffers few of  the consequences.

The statute does not rest on the assumption that males are generally the aggressors. It is instead an attempt by a legislature to prevent illegitimate teenage pregnancy by providing an additional deterrent for men. The Equal Protection Clause does not mean that the physiological differences between men and women must be disregarded. Judgement affirmed.


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