Mary Beth Barksdale
In Watson v. State, 487 P.3d 568 (Alaska 2021), the supreme court upheld Alaska Statute 47.12.030 as constitutional under the Alaska Constitution’s equal protection clause. (Id. at 570). The defendant was a minor convicted on two counts of misdemeanor DUI. (Id.). On appeal, the defendant argued that the criminal statute, which provided that juvenile defendants of misdemeanor traffic violations would be tried in district court as adults, impermissibly violated the Alaska equal protection clause by creating overbroad categories of juvenile defendants – those charged with felony traffic offenses and those charged with non-felonious traffic offenses. (Id. at 571). The court, however, found no constitutional issue with the classifications. (Id.) The court therefore proceeded to apply the “three-step equal protection analysis.” (Id. at 572). First, the court found that defendants have special personal interest in rehabilitative treatment by the criminal system, and such interest requires a “close relationship” between the state interest at issue and the regulation of the individual interest, but the court recognized that it owed deference to legislative decisions to emphasize one sentencing goal over another in designing systems of crimes and punishments. (Id. at 572–73). Second, the court found that the government had important interests in both protecting the public and promoting rehabilitation. (Id. at 574–75). Lastly, the court found that the statute’s classification system was a closely related means both to preserve a consistent and graduated punishment system for misdemeanor traffic violations, protecting the public, and also to promoting rehabilitation of minors convicted of felonies, shielding them from the harsher punishments levied against adult felons in district court. (Id. at 573–76). Affirming the Court of Appeals, the supreme court upheld Alaska Statute 47.12.030 as constitutional under the Alaska Constitution’s equal protection clause. (Id. at 570).