Michael M. v. Superior Court of Sonoma County
"Michael M. v. Superior Court of Sonoma County" is a significant legal case that addresses the complexities of statutory rape laws in California, specifically focusing on the differential treatment of male and female offenders. Under the law at the time, men could be held criminally liable for engaging in sexual activities with underage girls, while women faced no such penalties, even when both parties were within a close age range. This law was justified by the state as a means of deterring potential pregnancies, highlighting a gender-specific approach to legal accountability.
The Supreme Court's ruling in this case was notably divided, with a plurality of justices upholding the statute while expressing varying views on its implications. Some justices concurred with the outcome but disagreed on the rationale, emphasizing the challenges of proving forcible rape in such cases. Dissenting opinions raised concerns about the fairness and logic of punishing only one party in a consensual act, suggesting that a more equitable legal framework was necessary.
This case opens up discussions about gender discrimination in the legal system, the effectiveness of existing laws in preventing unwanted pregnancies, and the broader implications of statutory rape laws on young people's rights and responsibilities. It serves as a pivotal example of how laws can reflect societal attitudes toward gender and sexuality, prompting ongoing debates about legal reform and gender equality.
Michael M. v. Superior Court of Sonoma County
Date: March 23, 1981
Citation: 450 U.S. 464
Issue: Sex discrimination
Significance: The Supreme Court upheld state laws saying men could commit statutory rape but women could not.
California law held men culpable for statutory rape but not women, even if both parties were within a narrow underage range, arguing that such a law acted more as a deterrent to pregnancy than a gender-neutral law would because the young woman was needed as a witness to the crime. A Supreme Court plurality of four accepted this view, upheld the statute, and sustained the conviction of “Michael M.” The Court was anything but unified on the case. Justice Harry A. Blackmun concurred in the result but did not join in the opinion, thereby creating a 5-4 vote but only a four-member plurality opinion. Based on his quotation of lengthy extracts from the trial Blackmun appeared to feel that the case was a hard-to-prove forcible rape case. Potter Stewart wrote a separate concurrence. Justice William J. Brennan, Jr., dissented and was joined by Byron R. White and Thurgood Marshall. They argued that California had not proved its law was a greater deterrent to pregnancy than a more gender-balanced law would have been. Justice John Paul Stevens dissented separately, arguing that a law that punished one of two parties to a consensual act was illogical, and this problem could perhaps be avoided if the law punished the aggressor or more willing party.
