Lalli v. Lalli – Child Rights
Lalli v. Lalli, 431 U.S. 911, 97 S. Ct. 2164, 53 L. Ed. 2d 220 (1977).
NATURE OF THE CASE: This was an appeal challenging the constitutionality of a state classification that created a disadvantage for children of unmarried parents.
FACTS: Petitioner Robert Lalli was born out of wedlock to Mario Lalli who died intestate. Mario’s widow denied Robert and his sister inheritance from Mario’s estate. However, before his death, Mario had held both children out to be his own as evidenced by affidavits of people that knew Mario. A New York law allowed intestate succession by ‘illegitimate’ children provided there was proof of paternity. Under New York law, paternity is asserted via a formal declaration during the mother’s pregnancy or within two years of a child’s birth. Robert Lalli asserted that this law discriminates against him in violation of the Fourteenth Amendment Equal Protection Clause. The Surrogate Court held against Robert Lalli and the New York Court of Appeals twice affirmed. The U.S. Supreme Court granted cert.
ISSUES: 1) Is a statute that denies inheritance to children born to unmarried parents valid in light of the Fourteenth Amendment Equal Protection Clause? 2) Is it constitutionally permissible for state law to require a child to bear the burden of proof of paternity in order to inherit?
RULE OF LAW: 1) Yes. A statute that denies inheritance to children born to unmarried parents is valid in light of the Fourteenth Amendment Equal Protection Clause. 2) Yes. It is constitutionally permissible for state law to require a child to bear the burden of proof of paternity in order to inherit.
HOLDING AND DECISION (Powell): When a classification is based on legitimacy, the Court will use an intermediate level standard of review. The Court will strike down the statute unless it is shown to be important to the achievement of a substantial government objective. A state statute is not unconstitutional if it does not impose an inordinate burden on illegitimate children in order to advance a state administrative interest.
In Trimble v. Gordon, 430 U.S. 762 (1977), the Supreme Court invalidated a similar state statute that denied inheritance to illegitimate children. In that case, the father never acknowledged his illegitimate children but was nevertheless determined to be the father by a judicial declaration of paternity. The state advanced its interests in administrative convenience in determining inheritance and in preserving the family unit. The statute in Trimble was invalidated however because it placed an exceptional burden on illegitimate children by requiring actual marriage of their parents in order to revive inheritance benefits. Trimble is distinguishable from the case at bar because in this case the marital status of the parents is irrelevant. No heavy burden of paternity is required.
The New York law allows fathers to prove paternity at any time before death. The goal of the statute is to provide for the just and orderly disposition of property at death. This is a valid state interest because paternity is a difficult evidentiary task. Therefore, illegitimate children may not be treated the same as legitimate children because proof of relationship can sometimes be lacking, thereby exacerbating difficulties associated with property distribution. These concerns are minimized when the father declares paternity through a judicial process. While the state law may be unfair it can be connected to a substantial government interest and is therefore valid.
DISPOSITION: Affirmed.
Concurring (Stewart): The Court adequately demonstrates the differences between Trimble v. Gordon and the facts in the present case. Therefore, Justice Rehnquist’s dissenting opinion is invalid.
Concurring (Blackmun): The Court should overrule Trimble v. Gordon rather than distinguish it. If the Court does not overrule Trimble, the Court will be required to validate or invalidate every future statute as falling under Trimble or under Lalli.
Dissenting (Brennan): The New York statute imposes just as high an evidentiary burden as that in Trimble. While Trimble requires marriage, Lalli accepts only a judicial declaration of paternity.