People v. Lynch
209 Cal. App. 4th 353
| Cal. Ct. App. | 2012Background
- Lynch pleaded no contest to methamphetamine possession with a prior narcotics conviction and failure to appear; sentenced June 7, 2011 to four years, four months in state prison.
- Realignment Act (2011) significantly redefines a felony to include county jail confinement with possible supervision under § 1170(h); effect varies by operation date.
- Realignment includes a savings clause limiting its application to defendants sentenced on or after October 1, 2011.
- Lynch would have benefited from the Realignment Act if sentenced after October 1, 2011, but his sentence predates that date.
- Defendant argues prospective application of the Realignment Act violates equal protection; the court analyzes whether this is permissible without applying retroactive benefits.
- Court concludes prospective application does not offend equal protection because no fundamental liberty interest or suspect class is implicated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prospective application of the Realignment Act violates equal protection | Lynch contends timing creates discrimination against earlier-sentenced offenders. | State argues no fundamental right or suspect class; rational basis supports prospective application. | No equal protection violation; prospective use upheld. |
| Whether Saffell governs equal protection for a more beneficial sentencing change | Saffell should preclude distinguishing by sentence date for benefits. | Saffell involved a different scheme; not controlling for sentencing reductions. | Saffell distinguished; not controlling; prospective application allowed. |
| Whether Floyd’s reasoning on effective vs operative dates applies to Realignment | Argues Floyd distinguishes based on operative vs effective date to deny retroactivity. | Distinction without difference; Floyd involved the same concept of prospective application. | Floyd applies; prospective application permissible. |
Key Cases Cited
- People v. Floyd, 31 Cal.4th 179 (Cal. 2003) (prospective application of reduced punishment upheld)
- Saffell, 25 Cal.3d 223 (Cal. 1979) (equal protection and liberty interests in special offender statutes)
- Baker v. Superior Court, 35 Cal.3d 663 (Cal. 1984) (prospective repeal of laws not violating equal protection)
- Kapperman, 11 Cal.3d 542 (Cal. 1974) (prospective application of sentencing credit reductions withstands equal protection)
- In re Huffman, 42 Cal.3d 552 (Cal. 1986) (experimental programs in equal protection context)