## Facts

- California voters enacted Proposition 21, which authorized prosecutors to file specified juvenile felony cases directly in adult criminal court without a prior judicial fitness hearing.
- Morgan Victor Manduley, Michael Rose, and other minors were charged with serious felonies and prosecuted in adult court under the direct-file provisions.
- The minors sought writ relief, arguing the direct-file scheme was unconstitutional on multiple grounds, including separation of powers, the single-subject rule, due process, and equal protection.
- The Court of Appeal rejected the challenges and upheld the provisions.
- The California Supreme Court granted review and consolidated the matters to decide the constitutional attacks on Proposition 21’s direct-file scheme.

## Issues

1. Whether granting prosecutors discretion to file certain juvenile cases in adult court, bypassing a judicial fitness hearing, violates separation of powers or constitutes an impermissible delegation of legislative or judicial authority under the California Constitution.
2. Whether Proposition 21 violates the California Constitution’s single-subject rule or otherwise exceeds the initiative power.
3. Whether eliminating a judicial fitness hearing and permitting direct filing in adult court violates juveniles’ due process rights.
4. Whether the direct-file classifications or prosecutorial discretion deny equal protection.
5. Whether the scheme is facially invalid as cruel or unusual punishment under the California Constitution (or the Eighth Amendment) because it exposes juveniles to adult sentencing.

## Decision

- The California Supreme Court denied the petitions and upheld Proposition 21’s direct-file provisions.
- The Court held the initiative did not violate separation of powers because charging decisions are an executive function and the initiative defined jurisdictional consequences tied to the filing decision.
- The Court held Proposition 21 satisfied the single-subject rule because its provisions were reasonably germane to the common purpose of addressing gang violence and juvenile crime.
- The Court held due process was not violated because there is no constitutional right to juvenile treatment or to a judicial fitness hearing, and minors tried as adults retain full criminal procedural protections.
- The Court held the scheme did not violate equal protection because the classifications were subject to rational basis review and were reasonably related to legitimate governmental objectives; discriminatory enforcement was not presumed and was not shown.
- The Court rejected a facial cruel-or-unusual-punishment challenge, reasoning that proportionality objections to particular sentences are case-specific and the initiative primarily set forum and exposure rather than mandating a specific punishment.

## Legal Principles

- The initiative power is coextensive with legislative power; under the single-subject rule, an initiative is valid when its provisions are reasonably germane to a common purpose.
- Prosecutorial discretion over whether to prosecute and what charges to file is a core executive function; tying adult criminal court jurisdiction to specified charging choices does not necessarily confer judicial power on prosecutors.
- Juvenile court jurisdiction and transfer procedures are statutory; absent a constitutional guarantee, the Legislature or electorate may alter or eliminate a judicial fitness hearing for defined categories of offenders.
- Juveniles are not a suspect class for equal protection purposes in this context; classifications based on offense seriousness, age, and criminal history are reviewed for rationality and may be justified by public safety and deterrence goals.
- Facial proportionality challenges to sentencing exposure generally fail where the law does not mandate a particular sentence and individualized challenges remain available after sentencing.

## Conclusion

The California Supreme Court upheld Proposition 21’s prosecutorial direct-file scheme, concluding that shifting transfer control from judges to prosecutors for specified juvenile felonies does not violate the single-subject rule, separation of powers, due process, equal protection, or facial proportionality limits on punishment.


Manduley v. Superior Court, 27 Cal. 4th 537 (Cal. 2002)