Dean v. People

Summary

The court held that Colorado's habitual-criminal sentencing and parole-eligibility scheme, as applied to Dean, does not violate equal protection even though his parole eligibility date was later than that of an offender sentenced to life imprisonment for more serious prior offenses. Applying rational-basis review, the court found the scheme rationally related to punishing recidivists, protecting public safety, and encouraging rehabilitation, and held that comparative sentence severity is measured principally by the potential term of imprisonment rather than parole eligibility. The court affirmed the court of appeals and remanded for correction of the mittimus.