Reed v. Reed

404 U.S. 71, 92 S. Ct. 251 (1971)

 

RULE:

U.S. Const. amend. XIV does not deny to states the power to treat different classes of persons in different ways. The equal protection clause, U.S. Const. amend. XIV does, however, deny to states the power to legislate that different treatment be accorded to persons placed by a statute into different classes on the basis of criteria wholly unrelated to the objective of that statute. A classification must be reasonable, not arbitrary, and must rest upon some ground of difference having a fair and substantial relation to the object of the legislation, so that all persons similarly circumstanced shall be treated alike.

FACTS:

When a minor died intestate, appellant mother and appellee father, who had separated before the child's death, each filed a petition with the probate court seeking appointment as administrator of the deceased minor's estate. The probate court appointed appellee father as administrator of the estate, relying on Idaho Code §§ 15-312, 15-314 (repealed 1972) that gave preference within a designated class of persons to males over females. During the appeal process of the probate court's decision, the state supreme court upheld the constitutionality of the statutes. The court reversed the judgment of the state supreme court. 

 

ISSUE:

Does a statute that includes a gender based provision, preferring males over females to administer an estate, violate the Equal Protection Clause of the Fourteenth Amendment of the Constitution?

ANSWER:

Yes.

CONCLUSION:

The court held that Idaho Code §§ 15-312, 15-314 violated the equal protection clause, U.S. Const. amend. XIV. The court held that the state interest in reducing one level of contests in the probate courts had some legitimacy, but that a statute could not give mandatory preference to members of one sex over the other merely to eliminate the need for hearings on the merits. The court held this was the type of arbitrary legislative choice forbidden by the equal protection clause, U.S. Const. amend. XIV.

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