Clark v. Jeter
Citing Weber v. Aetna Casualty & Surety Co. (1972), Justice O'Connor noted that the Court had ruled restrictions that "burden illegitimate children for the sake of punishing the illicit relations of their parents" are unconstitutional. In three previous cases concerning paternity claims by illegitimate children, Justice O'Connor wrote, restrictions on the child's right to obtain paternal support were found to violate the Equal Protection Clause to the Fourteenth Amendment. In Gomez v. Perez (1973), the Court struck down a Texas law that denied illegitimate children the right to sue for paternal support while granting that right to legitimate children. The Court ruled that "once a state posits a judicially enforceable right on behalf of children to needed support from their natural fathers there is no constitutionally sufficient justification for denying such an essential right to a child simply because its natural father has not married its mother." In Mills v. Hableutzel (1982), the Court struck down a Texas one-year statute of limitations for paternity claims, ruling that this period of time was insufficient to give an illegitimate child "reasonable opportunity" to bring a paternity claim. And in Pickett v. Brown (1983), the Court struck down a Tennessee law imposing a two-year limit on paternity claims. In these cases, the Court identified two criteria by which to evaluate statutes of limitations on paternity claims. First, the period during which an illegitimate child could bring a claim must be of reasonable length to protect the child's interests. Second, any time restriction must be necessary to prevent the litigation of "stale or fraudulent" claims against a putative father, who might have difficulty establishing evidence in his defense after the passage of time.
Justice O'Connor indicated that in Mills v. Hableutzel, the Court reasoned that the mother of an illegitimate child would be likely to experience emotional and financial complexities during the child's first year and might find it difficult to bring a paternity claim during that brief time. Furthermore, the Court rejected the argument that this time limit was necessary to avoid fraud because it would be unlikely that evidence a putative father could use in his defense would be lost during the course of one year. Extending this reasoning to Pickett v. Brown, the Court ruled that Tennessee's two-year statute of limitations was also too short, and that the time limit was not necessary to prevent problems of proof or fraudulent claims, since new blood testing procedures could establish proof of paternity with good reliability.
In Clark v. Jeter, the Court found that Pennsylvania's six-year statute of limitations violated the Equal Protection Clause of the Fourteenth Amendment. Justice O'Connor wrote, "Even six years does not necessarily provide a reasonable opportunity to assert a claim on behalf of an illegitimate child" and noted that psychological and social issues might prevent a mother of a child born out of wedlock from pressing a claim within this time period. Justice O'Connor also reasoned that financial difficulties would be likely to increase as a child grew older. "Thus is it questionable whether a State acts reasonably when it requires most paternity and support actions to be brought within six years of an illegitimate child's birth."
The Court also rejected the argument that Pennsylvania's six-year statute of limitation was necessary to prevent fraud in paternity claims. Pennsylvania allowed paternity suits to be brought more than six years after the illegitimate child's birth if the suit was brought within two years of a support payment by the father, and imposed no time limits on some other types of paternity litigation. Pennsylvania's inheritance laws permitted an illegitimate child to bring a paternity suit as long as there was "clear and convincing evidence" that the alleged father was the child's father. And Pennsylvania imposed no statute of limitations on a father's right to establish paternity. Furthermore, the Court reasoned, Pennsylvania's new law establishing an 18-year statute of limitations "is a tacit concession that proof problems are not overwhelming."
Moreover, the Court noted that advances in biotechnology have changed the ways in which proof of paternity is established. In previous years, evidence of paternity was not scientifically accurate and paternity claims were difficult to prove or defend after the passage of time. Sophisticated DNA testing, however, can eliminate over 99 percent of those falsely accused of fathering a child and can be administered at any time. The availability of this reliable testing, wrote Justice O'Connor, "is an additional reason to doubt that Pennsylvania had a substantial reason for limiting the time within which paternity and support actions could be brought." In a unanimous decision, the Supreme Court ruled that Pennsylvania's six-year statute of limitations violated the Equal Protection Clause of the Fourteenth Amendment and remanded the case for further proceedings.
Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1981 to 1988Clark v. Jeter - Significance, New Directions In Family Law, Important Precedents, Impact, Pro And Con: Dna Testing