Levy v. Louisiana - An Important Reversal

In addressing the rights of illegitimate children, Levy was the first Supreme Court case recognizing that illegitimate children may have the same rights as legitimate children under the Equal Protection Clause. The ruling provided a basis for later rulings concerning legitimacy related to workers' compensation survivors benefits in Weber v. Aetna Casualty & Surety Co. (1972), and social security benefits in Mathews v. Lucas (1976). The Court found in Weber that penalizing individuals for something they had no responsibility for, the conduct of their parents before they were born, was highly unjust under the law. The Court also supported a mother recovering wrongful death damages for the death of an illegitimate son in Glona v. American Guarantee and Liability Insurance Co. (1968).

Regarding inheritance issues, the Court was less consistent in recognizing the rights of illegitimate children. The Court ruled in Labine v. Vincent (1971) that a state could prohibit illegitimate children from claiming inheritance from a father who left no will. The decision actually followed the same line of reasoning as Harlan's dissenting comments in Levy. The Court should not be so quick to override the state's authority to regulate its citizens. The Court later wavered in close votes on other inheritance rulings. In family law, Levy was one of several crucial rulings that began defining children's rights.