not enough emphasis on the fundamental question of whether the sex-based discrimination in the California statute is substantially related to the achievement of that goal." The dissenters felt that Rehnquist's opinion emphasized the goal of the state without any regard to the means or to the actual question at hand. They questioned whether gender-neutral statutory rape law would actually be harmful to California's goal of lowering teen pregnancy rates, since no evidence that a gender-biased law would be beneficial was provided. Justice Brennan wrote, "[t]he burden is on the government to prove both the importance of its asserted objective and the substantial relationship between the classification and that objective. And the State cannot meet that burden without showing that a gender-neutral statute would be a less effective means of achieving that goal." Without any factual evidence or comparison, according to the dissenters it is difficult to tell whether a gender-biased statute actually lowers teen pregnancy rates. Brennan also cited that at the time of the trial, thirty-seven other states had adopted gender-neutral statutory rape laws. He hypothesized that gender-neutral laws might be a greater deterrent than non-gender neutral laws because there would be "twice as many potential violators." Justice Stevens added that he thought there was no reason to not include a woman in the law because women are "capable of using [their] own judgment of whether or not to assume the risk of sexual intercourse". Significance The Michael M. v. Superior Court of Sonoma County case upheld that gender biased statutory rape laws did not violate the Equal Protection Clause of the Fourteenth Amendment to the Constitution. It demonstrated that laws can be applied differently to men and women and remain constitutional as long as the state can justify doing so. Controversy surrounding the case There is some controversy surrounding not the case or the issue itself, but rather the original charge Michael M. was faced with. Some critics of the case question why the defendant was charged with statutory rape and not with forcible rape. Because Michael exerted force on Sharon until she submitted to sex, some believe that, "[t]his is a case of forcible rape. But neither the California courts nor the Supreme Court saw it that way, and this was exactly what some feminists feared. Even though Sharon said no and was punched, this case was immediately charged with statutory rape." Justice Blackmun addressed these concerns: