## Facts

- Several plaintiffs, including male domestic-violence victims and a victim’s daughter, sued California public health officials responsible for administering state-funded domestic violence programs and certain correctional programs.
- State domestic violence statutes defined domestic violence and funded services in terms that effectively limited eligibility for state-funded victim services to women.
- David Woods alleged long-term spousal abuse, sought assistance from a service provider, and was denied services because the provider did not accept men; he alleged an ongoing need for services.
- Other male plaintiffs alleged similar denials of access to services due to their sex.
- Plaintiffs submitted evidence that men suffer domestic violence, need the same forms of assistance as women (e.g., safe housing and counseling), and could be served through gender-neutral or operationally separate arrangements.
- Plaintiffs also challenged statutes creating alternative sentencing and community-based treatment programs for incarcerated women who were pregnant or mothers of very young children.
- The record indicated incarcerated mothers were more likely than incarcerated fathers to have been primary caregivers, and no incarcerated father was shown to meet the programs’ eligibility requirements as structured.
- The trial court denied relief, finding men not similarly situated to women for either statutory scheme; it also rejected other theories (including Proposition 209 and related Government Code claims) on procedural and standing grounds.

## Issues

1. Whether excluding male victims from state-funded domestic violence programs violated equal protection because male and female victims were similarly situated for the programs’ purposes.
2. Whether limiting alternative sentencing and treatment programs to inmate mothers violated equal protection by discriminating against male inmates.
3. Whether plaintiffs were entitled to relief under Proposition 209 and related Government Code provisions, including a challenge to an exception allowing certain lawful programs benefiting women.

## Decision

- The Court of Appeal reversed in part and affirmed in part.
- It held the domestic violence statutes’ gender-based classifications violated equal protection because male victims were similarly situated to female victims for purposes of victim-protection programs and no sufficient governmental justification supported categorical exclusion.
- As a remedy, it reformed the domestic violence statutory scheme by invalidating the male exclusion and extending program benefits to men, rather than striking the statutes in full.
- It affirmed the judgment as to the inmate mother programs, concluding plaintiffs failed to show male inmates were similarly situated to female inmates for purposes of those programs on the record presented.
- It rejected plaintiffs’ remaining contentions, including Proposition 209-related claims and the challenge to the Government Code provision, including for lack of standing.

## Legal Principles

- Equal protection analysis requires a threshold showing that the compared groups are similarly situated with respect to the statutory purpose; if not, differential treatment does not trigger the same constitutional infirmity.
- Sex-based exclusions from broadly framed victim-services programs violate equal protection when both sexes are similarly situated regarding the program’s purpose and the State lacks a sufficiently strong justification for categorical exclusion.
- When a statutory benefit is unconstitutional due to an improper exclusion, a court may preserve the legislative program by severing the exclusion and extending benefits to the excluded group where that best serves legislative intent.
- Sex-specific correctional programs may be upheld where the statutory objective and record evidence show meaningful differences relevant to the program’s purpose and where prison-administration judgments warrant judicial deference.

## Conclusion

The court required state-funded domestic violence services to be available to male victims on equal terms by removing statutory sex-based exclusions, but it upheld women-only inmate-mother programs because plaintiffs did not establish that male inmates were similarly situated to inmate mothers for the programs’ targeted purposes.


Woods v. Horton, 167 Cal. App. 4th 658 (Cal. Ct. App. 3d Dist. 2008)