## Facts

- Thelma B. Stanton and James Lawrence Stanton, Jr. divorced in Utah in 1960.
- The divorce decree required James to pay monthly child support for their two children, a daughter and a son.
- Utah law set the age of majority at 21 for males and 18 for females, affecting when parental support obligations ended.
- When the daughter turned 18, James stopped paying support for her but continued paying for the son.
- Thelma moved in Utah court to require support for the daughter until age 21; the trial court denied relief based on the statute.
- The Utah Supreme Court affirmed, finding the sex-based classification reasonable under equal protection.
- Thelma appealed to the U.S. Supreme Court.

## Issues

1. Whether the case was moot or Thelma lacked standing because the disputed support period had passed by the time of Supreme Court review.
2. Whether Utah’s sex-based age-of-majority statute, as applied to parental support obligations, violated the Equal Protection Clause of the Fourteenth Amendment.

## Decision

- The Court held the case was not moot because, if support was legally owed from ages 18 to 21, unpaid amounts could remain due.
- The Court held Thelma had standing because Utah law imposed on her a legal duty to support her daughter to age 21, directly affecting her financial interests.
- The Court held the statute’s different ages of majority for males and females, as used to extend support obligations for sons beyond daughters, denied equal protection.
- The judgment was reversed and remanded for state-court resolution of how to eliminate the unconstitutional discrimination and whether additional support was owed.

## Legal Principles

- Sex-based classifications must be reasonable and nonarbitrary and must bear a fair and substantial relation to the statute’s objective.
- Generalized assumptions about gender roles and maturation are not a sufficient justification for treating sons and daughters differently in parental support obligations.
- A law extending parental support for sons beyond daughters based on different sex-defined ages of majority violates equal protection, at least where the classification fails even rational-basis review.
- When a state law is unconstitutional due to unequal treatment, the method of equalizing treatment is generally a question of state law on remand, so long as equal protection is satisfied.

## Conclusion

The Supreme Court held that Utah could not constitutionally use different sex-based ages of majority to impose longer child-support obligations for sons than for daughters; the case was not moot, the mother had standing, and the matter was remanded for Utah courts to determine a nondiscriminatory rule and any arrearages.


Stanton v. Stanton, 421 U.S. 7 (1975)