Facts
- Richard Lynn Reed, the adopted son of Sally M. Reed and Cecil R. Reed, died intestate in Ada County, Idaho in 1967, leaving a small estate.
- Sally Reed (mother) and Cecil Reed (father), who were separated, each petitioned the probate court to be appointed administrator of the estate.
- Idaho’s probate code directed that when eligible persons applied from the same statutory class, “males must be preferred to females.”
- The Ada County Probate Court appointed Cecil Reed as administrator solely because he was male, treating the statutory preference as mandatory.
- Sally Reed challenged the appointment on federal constitutional grounds, arguing that the sex-based preference denied equal protection.
Issues
- Whether a state statute requiring that “males must be preferred to females” in appointing estate administrators, when applicants are otherwise similarly eligible, violates the Equal Protection Clause of the Fourteenth Amendment.
- Whether administrative efficiency can justify a categorical sex-based rule that resolves contests for letters of administration without a hearing on the merits.
Decision
- The Supreme Court unanimously reversed the judgment upholding the Idaho statute.
- The Court held that the mandatory preference for men over women in selecting estate administrators is unconstitutional under the Equal Protection Clause.
- The Court ruled that using sex as an automatic tie-breaker to avoid hearings is an arbitrary legislative choice forbidden by the Fourteenth Amendment.
- The case was remanded for further proceedings consistent with the Court’s opinion.
Legal Principles
- A statute that explicitly classifies persons by sex is subject to Equal Protection review.
- A classification must be reasonable, not arbitrary, and must rest on a ground of difference that bears a fair and substantial relation to the statute’s objective.
- Administrative convenience and workload reduction, standing alone, do not justify a blanket rule that prefers one sex over the other when applicants are in the same entitlement class.
- The state may not mandate appointment decisions solely on the basis of sex when the selection can be made by considering individual qualifications.
Conclusion
The Court invalidated Idaho’s mandatory male-preference rule for estate administrators, holding that resolving appointments by sex to save time in probate proceedings denies equal protection because the classification is arbitrary and lacks a fair and substantial relation to the asserted administrative objective.