Law School Case Brief
Zablocki v. Redhail - 434 U.S. 374, 98 S. Ct. 673 (1978)
When a statutory classification significantly interferes with the exercise of a fundamental right, it cannot be upheld unless it is supported by sufficiently important state interests and is closely tailored to effectuate only those interests.
A Wisconsin statute, Wis. Stat. § 245.10 (1973), prevented any resident from marrying if they were behind in their child support obligations or if the children to whom they were obligated were likely to become public charges. Pursuant to § 245.10, appellee Redhail, a Wisconsin resident, was unable to enter into a lawful marriage in Wisconsin or elsewhere so long as he maintains his Wisconsin residency. Redhail filed a complaint in the district court, on behalf of himself and the class of all Wisconsin residents who had been refused a marriage license pursuant to § 245.10(1) by one of the county clerks in Wisconsin. The statute was attacked on the grounds that it deprived Redhail, and the class he sought to represent, of equal protection and due process rights secured by the First, Fifth, Ninth, and Fourteenth Amendments to the United States Constitution. A three-judge District Court held that the statute was unconstitutional under the Equal Protection Clause of the Fourteenth Amendment and enjoined its enforcement.
Is the Wisonsin statute unconstitutional?
The U.S. Supreme Court affirmed the judgment holding that the Wisconsin limitations on obtaining a marriage license were unconstitutional. The Court found that the statute violated equal protection in that it directly and substantially interfered with the fundamental right to marry without being closely tailored to effectuate the state's interests. The Court noted that other future financial obligations were not curtailed, only those that might be associated with marriage. The Court further found that the effect of the statute was that more illegitimate children would be born.
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