Clark v. Jeter

In the second half of the twentieth century, changes in American society challenged traditional notions of family. Substantial increases in divorce rates, illegitimate births, and single-parent families created problems relating to the financial support of children. The welfare system struggled to cope with increased demands, while taxpayers complained about the burden of supporting children born out of wedlock. Welfare reforms encouraged mothers to identify fathers of illegitimate children to obtain financial support from them. But because putative fathers had a right to protect themselves from the risk of fraudulent claims, existing state statutes imposed time limits after which illegitimate children could no longer bring paternity actions.

On 11 June 1973, Cherlyn Clark gave birth to a daughter out of wedlock. Ten years later, Clark filed a support complaint on the child's behalf against Gene Jeter, the alleged father, in the Court of Common Pleas of Allegheny County, Pennsylvania. Blood tests showed a 99.3 percent probability that Jeter was the child's father, but the court entered judgment for Jeter because Pennsylvania law required paternity claims to be brought within six years of the birth of an illegitimate child. The mother argued that this law violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment to the U.S. Constitution, but the court rejected this argument. The mother appealed to the Superior Court of Pennsylvania.

While the appeal was pending, the Pennsylvania legislature, to comply with the federal Child Support Enforcement Amendments of 1984, changed the law that had established the six-year statute of limitations. The new law, passed on 30 October 1985, allowed paternity claims to be brought within 18 years of a child's birth. In Clark's appeal, however, the Superior Court ruled that the new law was not retroactive and that the six-year statute of limitations did not violate the Constitution.

The U.S. Supreme Court issued a writ of certiorari, directing the lower court to forward the case proceedings for review, and decided to take the case to consider issues of constitutionality. The Court did not address the argument that Pennsylvania's new 18-year statute of limitation was retroactive. Though it is usual for the Court to consider an issue of statutory interpretation before considering constitutional claims, in this case the Court determined that Clark had not presented an adequate federal pre-emption argument to the lower courts. Writing for the unanimous Court, Justice O'Connor noted that the "question of how to interpret the Pennsylvania statute ultimately is a matter of state law." Therefore, the Court went on to consider the equal protection claim.