Sunday, September 16, 2012

Lehr v. Robertson case brief

Lehr v. Robertson case brief summary
463 U.S. 248 (1983)

CASE SYNOPSIS:
On writ of certiorari to the Court of Appeals of New York, appellant putative father sought review of an order affirming the dismissal of the father's paternity petition and entering an order of adoption in favor of appellees, mother and stepfather. The putative father claimed a right to notice and an opportunity to be heard pursuant to the Due Process and Equal Protection Clauses of the Fourteenth Amendment, U.S. Const. amend. XIV.

OVERVIEW: The putative father lived with the mother before the birth of a daughter, who was born out of wedlock. The putative father failed to enter his name in the State of New York's "putative father registry," which would have triggered notice to him of pending adoption proceedings.

HOLDING:
The Supreme Court found that he never had any significant custodial, personal, or financial relationship with the child and that he waited two years to establish a legal tie.

ANALYSIS:
-The Court held that the State of New York adequately protected the putative father's inchoate interest in establishing a relationship with his daughter through the provision of laws authorizing formal marriage, through its statutory adoption scheme, and through the putative father registry.
-Further, it concluded that the Equal Protection Clause did not prevent a state from according two parents different legal rights where one had a continuous custodial responsibility for the child, while the other never established a relationship.
-In that neither the Due Process Clause or the Equal Protection Clause was found to support the putative father's claims, the judgment of the New York Court of Appeals was affirmed.

OUTCOME: The Court affirmed the judgment of the New York Court of Appeals, which held that the putative father was not denied a right to notice and an opportunity to be heard.

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