F087021
Cal. Ct. App.Jul 1, 2025Background
- Natharan Giovanni Ruiz was convicted by jury of multiple sex offenses against four girls he met through his church, including lewd acts upon a child, oral copulation or sexual penetration with a child 10 years old or younger, and contacting a minor to commit a sexual offense.
- The offenses occurred between 2009 and 2017, when Ruiz was in his 20s and the victims were all under 14 years old.
- Ruiz was sentenced to 150 years to life plus 6 years in state prison under California's One Strike law, which provides severe penalties for certain sex offenses committed against minors.
- Ruiz is statutorily excluded from youth offender parole consideration under Penal Code § 3051, subd. (h).
- On appeal, Ruiz challenged his exclusion from youth offender parole and the length of his sentence on state and federal constitutional grounds.
Issues
| Issue | Defendant's Argument | State's Argument | Held |
|---|---|---|---|
| Exclusion from youth offender parole (equal protection, facial challenge) | Exclusion violates equal protection because One Strike offenders cannot seek early parole, while youth convicted of first degree murder can | Legislature has rational basis—risk of recidivism and seriousness of offenses justify exclusion | Exclusion is constitutional per People v. Williams |
| Exclusion from youth offender parole (equal protection, as-applied) | Disparate racial impact and individual circumstances make his exclusion unconstitutional | No evidentiary record to support targeted analysis; can seek relief through other avenues | As-applied challenge fails; no sufficient basis for exception |
| Cruel and unusual punishment (Eighth Amendment) | Sentence of 150 years to life plus 6 years is grossly disproportionate, especially since some offenses involved touching over clothing | Claim is forfeited (not raised below) and, even so, length is not disproportionate to severity/impact of crimes | Claim is forfeited and without merit, sentence upheld |
Key Cases Cited
- People v. Williams, 17 Cal.5th 99 (Cal. 2024) (upheld exclusion of One Strike offenders from youth offender parole consideration under rational basis review)
- People v. Hardin, 15 Cal.5th 834 (Cal. 2024) (upheld exclusion of special-circumstance murderers from youth parole eligibility; noted ongoing racial disparities)
- People v. Franklin, 63 Cal.4th 261 (Cal. 2016) (process for youth offenders to present mitigating evidence relevant for parole)
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment proportionality for juvenile nonhomicide offenders)
- People v. Dillon, 34 Cal.3d 441 (Cal. 1983) (cruel or unusual punishment analysis under California Constitution)