Stradford v. Secretary Pennsylvania Department of Corrections, Nos. 21-2655 & 22-2027 (3d Cir. 2022)
Nature of Case: Plaintiffs were individuals granted parole in Pennsylvania who brought a class action lawsuit. Pennsylvania, in placing individuals granted parole in halfway houses in the community, considered “community sensitivity” as one concern for placement. This concern meant that individuals who were incarcerated for a sex offense and granted parole remained incarcerated for longer periods of time than individuals without a sex offense record.
Plaintiffs brought suit, alleging that the practice violated Equal Protection.
The federal trial court in the Eastern District of Pennsylvania held that Pennsylvania’s practice of considering community sensitivity was not rationally related to a legitimate state interest, and thus it violated Equal Protection. Defendants appealed.
Holding: The Third Circuit Court of Appeals reversed and remanded the decision of the district court, holding that (1) plaintiffs were not similarly situated with parolees who had not committed a sex offense, and (2) policy considering community sensitivity was rationally related to legitimate government interests. For those reasons, the Court concluded that Pennsylvania’s practices did not violate the Equal Protection Clause.