Stanton v. Stanton

After Thelma Stanton appealed to the U.S. Supreme Court, James Stanton's counsel attempted to show the Court that she lacked standing for two reasons. In giving the opinion for an 8- 1 Court, however, Justice Blackmun rejected both of these arguments. First, James had posited that the support issue was moot because, by the time the case went before the Court, Sherri was 21 years old, having reached her majority by any state's standard in February of 1974. Second, James tried to contend that because Thelma herself did not belong to the age group identified by the Utah statute, she therefore lacked a personal stake in the proceedings; and that furthermore she had agreed to Utah's definition of the age of majority when she signed the papers stipulating support payments back in 1960.

With regard to the first argument, Blackmun wrote that the claim of mootness

overlooks the fact that what is at issue is support for the daughter during her years between 18 and 21. If appellee, under the divorce decree, is obligated for Sherri's support during that period, it is an obligation that has not been fulfilled, and there is an amount past due and owing from the appellee.

Far from being moot, then, the issue at hand was "a continuing live case or controversy." As for James's claim that Thelma had no direct interest in the case, the Court similarly dismissed this: "We are satisfied that it makes no difference whether the appellant's interest . . . is regarded as an interest personal to appellant or as that of a fiduciary." As the person responsible for a minor child, the custodial parent in this situation (i.e., Thelma) would actually be the one who had a right to support money--not the minor child herself. Furthermore, the Uniform Civil Liability for Support Act, which had been in effect in Utah since 1957, stated that "Every woman shall support her child"; hence, "the appellant herself thus had a legal obligation under Utah law to support her daughter until Sherri became 21 . . . Her interest in the controversy . . . is distinct and significant and . . . assures . . . proper standing on her part."

Turning to the specific merits of the case, Blackmun addressed each side's position. Whereas the appellant contended that the statute denied equal protection, the appellee claimed in turn that it was a test of rationality--i.e., that the difference in ages of majority had a logical basis, and was not a result of discrimination. In evaluating these claims, the Court used Reed v. Reed (1971) as its guide. The earlier case had sprung from an equal protection challenge to an Idaho law which gave preference to males over females when it came to a question of who should act as administrator over the estate of a deceased child. In its ruling, which struck down the Idaho statute, the Court had adopted a position first established in Royster Guano Co. v. Virginia (1920), stating that "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.'"

Seen under the light of this logic, the Utah statute lacked rationality. This was particularly so with regard to the Utah court's position that females tend to marry earlier than males; since the law in that state indicated that "all minors obtain their majority by marriage," this was a meaningless point. More importantly, the Court held, whether or not one endorsed the "old notions" embodied in the Utah statute, the Utah court had imposed "criteria wholly unrelated to the objectivity of that statute." Not only was a minor a minor, the U.S. Supreme Court stated, whether male or female, but "no longer is the female destined solely for the home and the rearing of the family, and only the male for the marketplace and the world of ideas."

In a further statement of the changing positions of women, the Court continued:

Women's activities and responsibilities are increasing and expanding. Coeducation is a fact, not a rarity. The presence of women in business, in the professions, in government and, indeed, in all walks of life where education is a desirable, if not always necessary . . . is apparent and a proper subject of judicial notice. If a specified age of minority is required for the boy in order to assure him parental support while he attains his education and training, so, too, is it for the girl. To distinguish between the two on educational grounds is to be self-serving: if the female is not to be supported as long as the male, she hardly can be expected to attend school as long as he does, and bringing her education to an end earlier coincides with the role-typing society has long imposed.

After reviewing a variety of other state statutes regarding the ages of majority--including other statements in Utah's own code--the Court concluded that there was no rational basis for the law. Finally, it was the Court's judgment that Section 15-2-1 "denies the equal protection of the laws, as guaranteed by the Fourteenth Amendment."