People v. Chatman, 228 Cal. Rptr. 3d 379

Jody Chatman pleaded guilty to robbery in 2001 and received felony probation with a short jail term; the robbery conviction was dismissed under Penal Code §1203.4 in 2007 after completion of probation. He later was incarcerated following a 2008 DUI conviction.
Chatman petitioned in 2014 for a certificate of rehabilitation under Penal Code §4852.01 to pursue a community care license, but was statutorily ineligible because §4852.01(b) bars persons whose accusatory pleading was dismissed under §1203.4 if they were incarcerated after that dismissal.
§4852.01 treats former prisoners (those committed to state prison) differently: former prisoners remain eligible for certificates of rehabilitation even if subsequently incarcerated (§4852.01(a)).
The trial court denied Chatman’s petition; the Court of Appeal reversed, holding the distinction unconstitutional under equal protection principles. The California Supreme Court granted review.
The central legal question: whether §4852.01’s disparate eligibility rules for (1) former prisoners and (2) former probationers whose convictions were dismissed under §1203.4 but who were later incarcerated, survive rational-basis equal protection review.

Issue	Plaintiff's Argument (Chatman)	Defendant's Argument (People/AG)	Held
Whether §4852.01’s exclusion of subsequently incarcerated §1203.4-dismissed probationers from certificates of rehabilitation violates equal protection	The exclusion arbitrarily denies similarly situated rehabilitated felons (like former prisoners) the chance for judicial consideration and thus lacks any rational basis	The distinction is rational: it conserves scarce judicial/executive resources and reflects that §1203.4 already affords probationers some relief; subsequent incarceration reasonably signals lower likelihood of rehabilitation	The Court upheld §4852.01 as rationally related to legitimate state interests (resource allocation and differentiation of need), reversing the Court of Appeal

People v. Ansell, 25 Cal.4th 868 (Cal. 2001) (historical purpose and effects of certificate of rehabilitation scheme)
Johnson v. Department of Justice, 60 Cal.4th 871 (Cal. 2015) (rational-basis equal protection analysis under state and federal constitutions)
Newland v. Board of Governors, 19 Cal.3d 705 (Cal. 1977) (invalidating irrational statutory classification that exempted felons but not misdemeanants)
Heller v. Doe, 509 U.S. 312 (U.S. 1993) (describing the deferential nature of rational-basis review)
Plyler v. Doe, 457 U.S. 202 (U.S. 1982) (limiting resource-preservation justifications when classifications lack rational relation to purpose)