Shelters Can Live with Woods v. Horton

Publication Date

2009

Document Type

Article

Abstract

In Woods v. Horton, California’s Third District Court of Appeals ruled that a state Health & Safety Code section that funds domestic violence shelter services specifically for battered women and their children violates equal protection. Using the strict scrutiny standard of review, the court held that women and men are “similarly situated” with regard to domestic violence under the state’s Equal Protection Clause and anti-discrimination statutes. The court ordered the language in the code to be revised to make state funding for domestic violence shelter services gender neutral. The court ruled, however, that domestic violence services provided to men and women need not be identical because women are battered in significantly greater numbers than men and suffer greater injuries when battered. This article summarizes the background, the particulars of the case, and its implications.

Publication Title

Domestic Violence Report

Volume

15

Issue

1

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