Facts
- Cherlyn Clark, on behalf of her nonmarital daughter Tiffany (born June 11, 1973), sought to establish paternity and obtain child support from Gene Jeter in Pennsylvania.
- Clark filed a support complaint on September 22, 1983, about ten years after Tiffany’s birth.
- Court-ordered blood testing indicated a 99.3% probability that Jeter was Tiffany’s father.
- Jeter moved to dismiss under a Pennsylvania statute generally requiring paternity actions for nonmarital children to be commenced within six years of birth, barring support if paternity was not established within that time.
- The trial court entered judgment for Jeter and rejected Clark’s Fourteenth Amendment Equal Protection and Due Process challenges.
- While the appeal was pending, Pennsylvania enacted an 18-year limitations period for paternity actions; the state appellate court held the new statute did not apply retroactively and upheld the six-year statute’s constitutionality.
- The U.S. Supreme Court granted review to assess the six-year limitations period’s constitutionality as applied to nonmarital children’s paternity/support actions.
Issues
- Whether the six-year limitations period was invalid due to conflict with federal child support enforcement law (federal preemption).
- Whether Pennsylvania’s six-year limitations period for establishing paternity for nonmarital children, which barred support if paternity was not proven within that time, violated the Equal Protection Clause.
Decision
- The Court declined to decide the federal preemption issue because it was not adequately presented to, or decided by, the state court.
- The Court applied intermediate scrutiny to the illegitimacy-based classification.
- The Court held the six-year limitations period violated the Equal Protection Clause.
- The Court reversed the Pennsylvania Superior Court’s judgment in a unanimous opinion by Justice O’Connor.
Legal Principles
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Classifications based on illegitimacy are subject to intermediate scrutiny and must be substantially related to an important governmental objective.
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For limitations periods governing paternity/support actions for nonmarital children:
- The period must be sufficiently long to provide a reasonable opportunity to assert the child’s claim; and
- Any time limit must be substantially related to the state interest in avoiding stale or fraudulent claims.
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A state’s asserted anti-stale-claim justification is weakened where its broader legal scheme permits later litigation of paternity in other contexts.
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Legislative extension of the limitations period may be considered when assessing whether a shorter period is necessary to serve the stated governmental objective.
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Reliable scientific testing (including high-probability blood test evidence) reduces the force of arguments that longer filing periods create unacceptable risks of fraudulent or unprovable paternity claims.
Conclusion
The Court held that Pennsylvania’s six-year statute of limitations for paternity actions involving nonmarital children failed intermediate scrutiny because it did not provide an adequately justified and closely fitted time bar to the state’s interest in preventing stale or fraudulent claims, and therefore violated equal protection.