Facts
- William Herbert Orr and Lillian M. Orr divorced in Alabama in 1974, and the decree required William to pay Lillian $1,240 per month in alimony under Alabama alimony statutes.
- Alabama law authorized courts to order alimony payments from husbands to wives, but did not impose corresponding obligations on wives.
- In 1976, Lillian filed a contempt petition alleging William was in arrears on alimony.
- At the contempt hearing, William challenged the alimony statutes as unconstitutional sex-based classifications under the Equal Protection Clause, without seeking alimony for himself.
- Alabama courts rejected the equal protection challenge and enforced the alimony obligation.
Issues
- Whether the Supreme Court had jurisdiction to review the federal constitutional claim where the husband did not seek alimony and first raised the challenge during the contempt proceeding.
- Whether Alabama’s statutory scheme imposing alimony obligations on husbands, but not wives, violated the Equal Protection Clause of the Fourteenth Amendment.
Decision
- The Court found jurisdiction proper: William had a personal stake because invalidation of the statutes was his only route to relief from the alimony burden.
- The Court concluded there was no adequate and independent state ground barring review because the state courts addressed the federal claim on the merits.
- Applying heightened review for sex-based classifications, the Court held Alabama’s husband-only alimony statutes violated the Equal Protection Clause.
- The Court reversed the judgment upholding enforcement of the alimony obligation under the sex-based statutory scheme.
Legal Principles
- Sex-based classifications are subject to Equal Protection scrutiny and must serve important governmental objectives and be substantially related to achieving those objectives.
- A state may pursue support for needy spouses and may seek to remedy economic disadvantages associated with marriage, but sex cannot be used as a categorical proxy for need when individualized financial determinations are feasible.
- A law that provides benefits to well-off members of the favored sex while excluding needy members of the disfavored sex is not substantially related to asserted remedial goals.
- Remedial sex classifications must be carefully drawn and cannot rest on traditional role assumptions or broadly framed generalizations about men and women.
Conclusion
The Court invalidated Alabama’s gender-specific alimony statutes because requiring only husbands to pay alimony was not substantially related to important state interests where need and resources could be assessed through gender-neutral criteria.