Thursday, November 7, 2013

Michael M. v. Superior Court of Sonoma County case brief

Michael M. v. Superior Court of Sonoma County case brief summary
450 U.S. 464 (1981)

On certiorari, defendant challenged a judgment of the Supreme Court of California that denied his petition to set aside a criminal indictment charging him with violating Cal. Penal Code § 261.5. Defendant claimed that § 261.5, the statutory rape law, unlawfully discriminated on the basis of gender in violation of the Equal Protection Clause of the Fourteenth Amendment.

When defendant was just over 17 years old, he was charged in a criminal complaint in state court with violating Cal. Penal Code § 261.5 for having unlawful sexual intercourse with a female under the age of 18. Section 261.5 made men alone criminally liable for the act of sexual intercourse. Contending that the statute unlawfully discriminated against men, defendant filed a motion to set aside the information and complaint. The state courts denied the motion.

  • On certiorari, the U.S. Supreme Court rejected defendant's contention that § 261.5 violated the Equal Protection Clause of the Fourteenth Amendment. 
  • Specifically, the Court ruled that the State had a strong, legitimate interest in preventing illegitimate pregnancies because of the social and economic problems such pregnancies caused it and the woman to suffer. 
  • The Court further held that the statute was sufficiently related to that state interest to pass constitutional muster. 
  • Moreover, the statute was not overbroad in its application to prepubescent females who could not become pregnant. 
  • The statute did not impermissibly discriminate between the genders by punishing only the male when both parties were under the age of 18.


The Court affirmed the judgment. The statutory rape law did not violate the Equal Protection Clause because it was sufficiently related to the State's strong interest in preventing teenage pregnancy, it was not overbroad, and its application only to men when both parties were minors did not render it invalid.

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