## Facts

- Mario Lalli died intestate in New York.
- Robert M. Lalli claimed to be Mario’s nonmarital son and petitioned Surrogate’s Court for a compulsory accounting, seeking a share of the estate.
- New York EPTL § 4-1.2 allowed a nonmarital child to inherit from an intestate father only if, during the father’s lifetime, a court entered an order of filiation establishing paternity.
- The estate’s administratrix opposed Robert’s claim, asserting that he was not a lawful distributee because no lifetime filiation order had been obtained.
- Robert offered evidence of paternity and argued that § 4-1.2 unconstitutionally discriminated based on illegitimacy under the Fourteenth Amendment’s Equal Protection Clause.

## Issues

1. Whether New York EPTL § 4-1.2’s requirement of a lifetime judicial order of filiation as a condition of paternal intestate inheritance by a nonmarital child violates the Equal Protection Clause.
2. Whether the statute’s classification is substantially related to important state interests in accurate and orderly estate administration and in preventing fraudulent or stale paternity claims.

## Decision

- The Supreme Court affirmed the judgment upholding EPTL § 4-1.2.
- Applying intermediate scrutiny for illegitimacy classifications, the Court held the statute did not violate equal protection because it was substantially related to permissible state interests.
- The Court distinguished an earlier invalidated inheritance scheme that tied inheritance to legitimation through parental marriage, characterizing New York’s rule as an evidentiary requirement rather than a marital-status preference.
- The Court accepted as important state interests: (1) orderly and accurate disposition of a decedent’s property, and (2) reducing fraudulent, harassing, or stale claims where proof of paternity is harder after death.
- The Court concluded that channeling paternity proof into a formal judicial proceeding during the father’s life reasonably advanced those interests, even if the line drawn could exclude some otherwise valid claims.
- A dissent argued the lifetime requirement was unduly rigid and that less restrictive methods (such as allowing posthumous proof under a heightened evidentiary standard) could protect the state’s interests without broadly barring claims.

## Legal Principles

- Classifications based on illegitimacy are subject to intermediate scrutiny: they must be substantially related to permissible (important) state interests.
- A state may impose special evidentiary conditions on a nonmarital child’s right to inherit from an intestate father when the conditions are directed to reliable proof and orderly estate administration.
- In intestate succession, legislatures may employ general rules that favor certainty and finality in probate, even if those rules produce some inequitable outcomes, so long as the chosen line is substantially related to the state’s objectives.

## Conclusion

The Court upheld New York’s requirement that a nonmarital child obtain a judicial filiation order during the father’s lifetime to inherit from the father’s intestate estate, finding the evidentiary restriction substantially related to the state’s interests in accurate, orderly probate administration and in preventing fraudulent or stale paternity claims.


Lalli v. Lalli, 439 U.S. 259 (1978)