In People v. Williams, the Supreme Court held that Penal Code section 3051, subdivision (h), does not violate the Equal Protection Clause of the Fourteenth Amendment by excluding young adults convicted and sentenced for serious sex crimes under the One Strike law (Pen. Code, § 667.61) from youth offender parole consideration. The Supreme Court affirmed a decision by the Fourth District, Division One and disapproved two earlier decisions.
The majority opinion authored by Justice Jenkins explains that the Legislature had a rational basis to exclude One Strike offenders from early parole eligibility–while not excluding young adults convicted of murder—because of the risk of recidivism that One Strike offenders pose.
Justice Liu dissented, arguing that (1) the legislative history of the statute does not support the theory that the Legislature enacted due to concerns about recidivism, and (2) data shows that sex offenders recidivate at lower rates than non-sex offenders.