People v. Ruffin
200 Cal. App. 4th 669
Cal. Ct. App.2011Background
- Ruffin pled no contest to oral copulation in prison under a negotiated settlement, with the court to decide later if registration as a sex offender was required.
- Prosecution information charged Ruffin with oral copulation in prison and lewd conduct, plus two prior robberies enhancing penalties under three strikes law.
- At sentencing (May 28, 2010 to July 7, 2010), the court dismissed strikes and lewd conduct, but ordered Ruffin to register after determining the law required it.
- The trial court concluded that Ruffin must register as a sex offender under section 290, subdivision (a).
- Ruffin challenged the registration requirement as an equal protection violation, leading to an appellate equal protection analysis and remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does mandatory lifetime registration for Ruffin violate equal protection? | Ruffin argues the class of inmates who commit acts in prison is treated differently than guards. | The state has a rational basis to require registration for offenders under section 290. | The classification violates equal protection; remand for discretionary registration analysis. |
Key Cases Cited
- People v. Hofsheier, 37 Cal.4th 1185 (Cal. 2006) (three-tier equal protection scrutiny; rational basis in social policy cases)
- People v. Santibanez, 91 Cal.App.3d 287 (Cal. App. 1979) (maintenance of prison discipline as legislative purpose for 288a(e))
- People v. Bojorquez, 183 Cal.App.4th 407 (Cal. App. 2010) (deterrence of sexual abuse in custody; purposes of 289.6)
- Newland v. Board of Governors, 19 Cal.3d 705 (Cal. 1977) (classification framework for equal protection inquiries)
- FCC v. Beach Communications, Inc., 508 U.S. 307 (Supreme Court, 1993) (burden to negate every conceivable basis for classification)