People v. Olivas

In People v. Olivas (1976) 17 Cal.3d 236, the court addressed an equal protection challenge to statutes that divided misdemeanor offenders into two groups based on their ages. The statutes established a sentencing scheme that singled out offenders between the ages of 16 and 21 years for substantially longer periods of incarceration than all other offenders. ( Olivas, supra, 17 Cal.3d at pp. 239-242.) The defendant faced a commitment to the California Youth Authority for three years, whereas an adult would have faced only a six-month term in jail. The court reasoned that because incarceration was a deprivation of liberty, the classification-by-age scheme affected the defendant's " 'personal liberty interest.' " ( Id. at p. 245.) The court further concluded that liberty was a "fundamental" interest. ( Id. at pp. 246-251.) Among other things, the court explained that our system of justice exhibits great concern for procedures that may result in restricting liberty and that many of the specific guarantees of due process are, in essence, manifestations of our fundamental respect for personal liberty. ( Id. at p. 249.) The court found that the California Constitution "manifests an even stronger concern for unwarranted deprivations of personal liberty by the state than can be found in the due process clause of the Fourteenth Amendment, itself a strong protection against unwarranted deprivations of liberty." ( Id. at p. 250.) In all, the court stated, "No reason has been suggested, nor can we conceive of any, why the concern for personal liberty implicit in both the California and federal Constitutions is any less compelling in the defendant's case. We believe that those charters are no less vigilant in protecting against continuing deprivations of liberty than are their due process clauses in protecting against the initial deprivation of that liberty. We conclude that personal liberty is a fundamental interest, second only to life itself, as an interest protected under both the California and United States Constitutions." ( Id. at pp. 250-251.)