Charles Dean v. the People of the State of Colorado

Summary

The court held that applying Colorado's habitual-criminal sentencing and parole-eligibility statutes to Dean did not violate equal protection, even though he would become parole eligible later than an offender with more serious prior convictions who received a life sentence. Under rational-basis review, the statutes were reasonably related to punishment, public safety, and the seriousness of the triggering offense and criminal history. The court also held that comparative parole-eligibility timing is not dispositive when assessing the relative severity of sentences and remanded only to correct the mittimus.