Sign Up for Vincent AI
People v. Williams
West Codenotes
Negative Treatment Reconsidered
Fourth Appellate District, Division One, D074098, San Diego County Superior Court, SCD268493, Kenneth K. So, Judge
Nancy J. King and Rebecca P. Jones, under appointments by the Supreme Court, for Defendant and Appellant.
Xavier Becerra and Rob Bonta, Attorneys General, Michael J. Mongan, State Solicitor General, Lance E. Winters, Chief Assistant Attorney General, Julie L. Garland, Assistant Attorney General, Joshua Patashnik, Deputy State Solicitor General, Daniel J. Hilton and Steve Oetting, Deputy Attorneys General, for Plaintiff and Respondent.
Richard J. Sachs, retired Deputy District Attorney (San Diego), and Gregory D. Totten for the California District Attorneys Association as Amicus Curiae on behalf of Plaintiff and Respondent.
Under California’s youth offender parole statute (Pen. Code,1 § 3051), certain persons incarcerated for crimes committed at a young age may be eligible for early release on parole. One factor relevant to the decision to release is the offender’s amenability to rehabilitation based on recognized attributes of youth. Section 3051, however, expressly excludes certain groups from its purview, including defendants convicted of forcible sexual offenses and sentenced under the One Strike law (§ 667.61). (§ 3051, subd. (h) (§ 3051(h)).) By contrast, those convicted of murder (aside from young adults convicted of special circumstance murder) are not categorically excluded. (People v. Hardin (2024) 15 Cal.5th 834, 843, 318 Cal.Rptr.3d 513, 543 P.3d 960 (Hardin).)
Defendant Jeremiah Ira Williams was sentenced to an indeterminate prison term of 100 years to life plus 86 years two months for One Strike offenses he committed when he was 24 years old. Defendant contends that by categorically excluding young adults convicted of One Strike offenses, but not young adults convicted of murder without special circumstance, from the possibility of early release, section 3051 violates the equal protection guarantee of the federal Constitution. This unequal treatment, he asserts, is irrational based, in part, on the high court’s recognition in the Eighth Amendment context that "defendants who do not kill, intend to kill, or foresee that life will be taken are categorically less deserving of the most serious forms of punishment than are murderers." (Graham v. Florida (2010) 560 U.S. 48, 69, 130 S.Ct. 2011, 176 L.Ed.2d 825 (Graham).)
The Court of Appeal rejected defendant’s equal protection challenge, finding a rational basis for the differential treatment. For reasons that follow, we affirm the Court of Appeal’s judgment.
Over two days in the summer of 2016, then 24-year-old defendant committed numerous sexual offenses against two female victims in two separate incidents in San Diego.
On the evening of August 13, Doe 1 returned home after spending the day with friends. As she headed from the garage to her apartment, a man approached her and asked if she needed help carrying the items in her hands. She replied, "No." But he followed her, claiming he was looking for a friend’s apartment. As Doe 1 unlocked her front door, the man rushed toward her, knocked her down, and held a gun to her head while demanding money. Doe 1 gave him a necklace, her wallet, and cell phone. He then forced her into her apartment, where he choked her and demanded money and other valuables.
The man punched Doe 1 in the face, causing her to fall and fracture her face. He then removed her pants and dragged her to the bedroom, where he penetrated her vagina with his penis, digitally penetrated her vagina, and forced her to orally copulate him. Thereafter, he forced Doe 1 into her shower where he wiped her bleeding face and vagina with a washcloth. At some point, the man closed the shower curtain and left the apartment. Doe 1 remained in the shower for about 20 minutes, not knowing if the man was still inside her apartment. She then got out of the shower, and went to a neighbors’ apartment. She told her neighbors about the attack, and they drove her to the hospital. Doe 1 suffered severe physical and psychological trauma.
During the ensuing police investigation, Doe 1 viewed individuals at a physical lineup but was unable to identify defendant. She subsequently identified him at the preliminary hearing as her assailant. Investigators were also able to match defendant’s DNA to a sample recovered from Doe 1’s bedroom comforter.
On August 14, the day after Doe 1 was attacked, Doe 2 was working as a prostitute at a San Diego motel. She had previously posted an "ad" on the Internet notifying potential "clients" of her general location. A man contacted Doe 2 and said he had $200 and wanted an hour of her time. They agreed to meet that day at Doe 2’s motel room. When he arrived later that day, he entered Doe 2’s motel room and immediately asked to use the restroom. When he came out of the bathroom, he threatened her, asking if she "wanted to die." At some point, he grabbed her neck and choked her repeatedly. Doe 2 lost consciousness. When she awoke, she was bent over on the side of the bed and felt the man’s penis inside her anus.
She tried to fight the man off, but he continued to choke her. At one point during the assault, he pulled out a handgun and struck Doe 2 on the head with it. She broke free and ran to the window, which she opened and then screamed for help. The man grabbed some of his belongings and fled the scene. Doe 2 climbed out the window and called an acquaintance, Henry C., for help. Henry C. picked her up from the motel and drove her back to her apartment. She initially declined to go to the hospital because she believed she would get in "trouble" for engaging in prostitution. However, two days after the attack, she went with Henry C. to the hospital, where she received treatment and spoke to a police officer about the attack.
Doe 2 later identified defendant in a photographic lineup as her attacker. The DNA of blood samples taken from defendant’s handgun and from his chest matched Doe 2’s DNA. A jewelry box missing from Doe 1’s apartment was found in a backpack left in Doe 2’s motel room.
After concluding its investigation of the assaults against Doe 1 and Doe 2, the prosecution filed a 13-count information charging defendant for offenses perpetrated against both victims. The information alleged counts for robbery (§ 211; count 1); making criminal threats (§ 422; counts 2, 8, 9, 11); forcible rape (§ 261, subd. (a)(2); counts 3, 6); forcible penetration (§ 289, subd. (a); count 4); forcible oral copulation (§ 288a, subd. (c)(2)(A); count 5); burglary (§ 459; count 7); sodomy by use of force (§ 286, subd. (c)(2)(A); count 10); assault with a firearm (§ 245, subd. (a)(2); count 12); and false imprisonment by violence, menace, fraud, and deceit (§§ 236, 237, subd (a); count 13). Counts 1 through 8 were alleged to have been committed against Doe 1, and counts 9 through 13 were alleged to have been committed against Doe 2.
After presentation of evidence and jury deliberations, the jury found defendant guilty as charged on counts 1 to 9 and 11 to 13, and it found him guilty as to count 10 on the lesser included offenses of battery and assault (§§ 240, 242). It also found that he: (1) personally used a firearm as to counts 1, 3, 4, 5, and 6 (§ 12022.53, subd. (b)), and personally used a firearm as to counts 2, 7, and 11 (§ 12022.5, subd. (a)); (2) kidnapped Doe 1, committed the offenses against her in the commission of a burglary, and inflicted great bodily injury on her as to counts 3, 4, 5, and 6 (§§ 667.61, subds. (a), (c), (d), & (e) & 667.5); and (3) committed the burglary in count 7 with another person present other than an accomplice (§ 667,5, subd. (c)(2D). The jury did not find true the multiple victim allegations attached to counts 3 through 6. When he committed the offenses against Doe 1 and Doe 2, defendant was on felony probation for a 2013 offense of inflicting corporal injury on an intimate partner. (§ 273.5, subd. (a).)
Given the nature of counts 3, 4, 5, and 6 as One Strike offenses under section 667.61, the trial court sentenced defendant to four consecutive terms of 25 years to life for each of those counts. It imposed an additional 10 years pursuant to section 12022.53, subdivision (b) and 5 years pursuant to section 12022.8, for a total of 15 additional years on counts 3 through 6. With the remaining determinate terms, defendant’s total sentence was 100 years to life plus 86 years two months. The court also imposed fines and fees, including restitution to the two victims.
Defendant appealed, arguing in part that section 3051’s categorical exclusion of One Strike offenders, which rendered him ineligible for a youth offender parole hearing, violated his equal protection rights under the Fourteenth Amendment to the federal Constitution. The Court of Appeal rejected defendant’s claim, finding that the "threat of recidivism by violent sexual offenders" provides a rational basis for the Legislature to exclude One Strike offenders from section 3051’s early release provisions. At least one Court of Appeal has reached the opposite conclusion, sustaining an equal protection challenge to section 3051’s exclusion of One Strike offenders. (See People v. Edwards (2019) 34 Cal.App.5th 183, 246 Cal.Rptr.3d 40.)
We granted review to resolve this split of authority.
Section 3051 offers youth offenders committed for long prison terms an opportunity for early release on parole. It requires the Board of Parole Hearings (Board) to conduct a youth offender parole eligibility hearing to determine if, based on certain criteria involving the "[c]ontrolling offense,"2 the offender is eligible for...
Experience vLex's unparalleled legal AI
Access millions of documents and let Vincent AI power your research, drafting, and document analysis — all in one platform.
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting