"Where fundamental personal liberties are involved, they may not be abridged by the States simply on a showing that a regulatory statute has some rational relationship to the effectuation of a proper state purpose. Where there is a significant encroachment upon personal liberty, the State may prevail only upon showing a subordinating interest which is compelling. City of Carmel-By-The Sea, v. Young, 466 P. 2d 225, 232; 85 Cal. Rptr. 1 (1970).
Definition of SUBORDINATE
: placed in or occupying a lower class, rank, or position : inferior <a subordinate officer>
: submissive to or controlled by authority
a : of, relating to, or constituting a clause that functions as a noun, adjective, or adverb