Woods v. Horton

California statutes authorized certain programs for inmate mothers and programs for victims of domestic violence. Two programs provided for alternative sentencing for female prisoners who were pregnant or mothers to very young children, had a history of substance abuse, and were sentenced to relatively short prison terms for specified crimes. These inmate-mother programs required a woman to live with her infant or young child in community facilities and receive treatment services. Incarcerated mothers were far more likely to have been the primary caretakers of young children than incarcerated fathers, and no incarcerated father was shown to qualify for the alternative-sentencing-program requirements. In addition, two other programs provided services for victims of domestic violence such as housing and employment support; “domestic violence” was statutorily defined such that it could only occur to women. Funded shelters, therefore, served women only. A group of individuals consisting primarily of men who had suffered domestic violence (the challengers) (plaintiffs) sued the state and related parties (defendants), challenging the constitutionality of the programs on equal-protection grounds. The challengers’ evidence established that men suffered from domestic violence as well as women, that men could benefit from support services, and that it was important for incarcerated fathers to bond with their young children. A director of California’s prison system discussed differences between male and female inmates, male-specific programs that were available, and gender-neutral programs as to visitation. The trial court denied relief to the challengers, finding that male and female incarcerated parents and male and female domestic-violence victims were not similarly situated. The challengers appealed.