Saturday, December 7, 2013

Lalli v. Lalli case brief

Lalli v. Lalli case brief summary
439 U.S. 259 (1978)


CASE SYNOPSIS
Appellant illegitimate son challenged a judgment of the Court of Appeals of New York, which determined that N.Y. Est. Powers & Trusts Law § 4-1.2 (1967) did not discriminate against him in violation of equal protection by requiring him to prove paternity with a judicial order of filiation before allowing him to inherit from his father by intestate succession.

DISCUSSION
The Supreme Court affirmed the constitutionality of N.Y. Est. Powers & Trusts Law § 4-1.2(1967), which required appellant illegitimate son to prove paternity with a judicial order of filiation issued during the life of his father in order to inherit from his father by intestate succession. Although this requirement was not imposed on legitimate children or children born out of wedlock whose parents intermarried, the statutory obstacle did not discriminate against appellant in violation of equal protection. The state's primary goal in enacting the statute was to provide for the just and orderly disposition of property at death. The court determined that this was an important state interest implicated in appellant's case, considering the peculiar problems of proof that were involved in establishing paternity. The means employed by the state were substantially related to the important state interest where the judicial order of filiation issued during the life of the father promoted accurate resolution of paternity disputes and minimized disruption of estate administration.

CONCLUSION

  • The Supreme Court affirmed a judgment that held that a New York statute requiring appellant illegitimate son to prove his father's paternity with an order of filiation issued by a court during his father's life in order to inherit from his father was constitutional. 
  • The requirement was substantially related to the important state interest of proper disposition of intestate property.

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