Michael M. v. Superior Court of Sonoma County

The Court's opinion is significant because it gives an extraordinary amount of weight to a state's after-the-fact assertion of the original reason it enacted the statute. Additionally, though the statute may not have been carefully drawn at the outset, the Court determined that the resulting legal action was appropriate and legitimate. The overall legitimacy of the goal, and the relationship of the statute to that goal, rendered the sex-based classification of the statute permissible.

This decision may raise questions on other equal-protection issues such as how one is able to determine whether or not men and women are "similarly situated" with respect to the aim of the law. The decision also raised questions regarding in what respect and to what extent, men and women are supposed to be similarly situated for an appropriate gender-based classification to be made. These questions were not answered by the majority opinion and are therefore still open to interpretation. Though in the past the Court has determined that, with regard to the Equal Protection clause of the Fourteenth Amendment, a legal classification must be reasonable in relation to the objectives of the law, this may be subject to differing opinions on what is "reasonable." The Court must be very careful in how it interprets this clause. The results of such interpretation could be inconsistent at best, and in fact "the Supreme Court has successively imposed different constitutional frameworks for reviewing legislation that draws lines between the sexes."