People v. ChatmanAnnotate this Case
Chatman, convicted of robbery in 2001, was sentenced to five years of felony probation plus 180 days in jail. Two years later, Chatman was convicted of misdemeanor reckless driving with alcohol. In 2006-2007 both convictions were dismissed under Penal Code section 1203.4. In 2008, Chatman was convicted of misdemeanor driving under the influence and was sentenced to three years of probation plus 10 days of imprisonment. In 2014, Chatman was offered a job that required a community care license from the Department of Social Services. Although Chatman’s robbery conviction bars him from obtaining that license, the Department may grant an exemption if a prospective employee has a Section 4852.01 certificate of rehabilitation (Health & Saf. Code 1522(g)(1)(A)(ii)). Once former probationers have their convictions dismissed under section 1203.4, section 4852.01 renders them ineligible for a certificate of rehabilitation if they are subsequently incarcerated. Former prisoners –– whether subsequently incarcerated or not –– face no such restriction. Chatman claimed that the unequal treatment was unconstitutional. The Supreme Court of California rejected that argument. Section 4852.01’s eligibility criteria survive rational basis review. Former probationers, as opposed to former prisoners, can seek some relief from the effects of their convictions through section 1203.4, and so have less relative need for certificate of rehabilitation relief. Instead of choosing an arbitrary means of limiting access to certificates, legislators used subsequent incarceration as a means of determining which former probationers show the most promise for rehabilitation.