Facts
- Philip H. Kline and Bonita Kline Curtis were parents of three children; a 1991 support order required Kline to pay support.
- In 1993, Kline sought to terminate support for two children who had entered college.
- After the petition, the legislature enacted Act 62 of 1993, 23 Pa.C.S. § 4327, authorizing courts to order postsecondary educational support from parents who were separated, divorced, unmarried, or otherwise already subject to a support obligation.
- The statute did not impose a comparable court-enforceable duty on married parents in intact families.
- Kline challenged the statute as violating the Equal Protection Clause of the Fourteenth Amendment.
Issues
- Whether 23 Pa.C.S. § 4327 violates equal protection by making court-ordered postsecondary educational support available only to children whose parents are separated, divorced, unmarried, or already subject to a support order, but not to children of married parents.
Decision
- The Pennsylvania Supreme Court affirmed the trial court’s order declaring Act 62 unconstitutional and terminating Kline’s enforceable postsecondary support obligation under the statute.
- The court applied rational basis review because the statute did not involve a suspect classification and did not burden a fundamental right.
- The court held the classification—conditioning children’s access to a state-enforced remedy for college support on their parents’ marital status—lacked a rational relationship to a legitimate state interest.
Legal Principles
- Equal protection permits statutory classifications only when the disparate treatment is rationally related to a legitimate governmental objective under rational basis review.
- Postsecondary education is not a fundamental constitutional right; statutes affecting access to educational support obligations are generally reviewed for rationality unless a suspect class or fundamental right is implicated.
- A statute that grants a judicially enforceable remedy to one group of similarly situated young adults while denying it to another based solely on parental marital status is unconstitutional when the distinction is arbitrary and not reasonably connected to the statute’s stated aims.
Conclusion
The court invalidated Pennsylvania’s postsecondary educational support statute because it irrationally conditioned a child’s access to a court-enforceable college-support remedy on the marital status of the child’s parents, resulting in unequal treatment of similarly situated young adults in violation of the Fourteenth Amendment.