Clark v. Jeter
486 U.S. 456 (1988)
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Rule of Law:
A state statute of limitations that imposes a time limit for an illegitimate child to establish paternity for the purpose of obtaining support violates the Equal Protection Clause of the Fourteenth Amendment if the period is not sufficiently long to provide a reasonable opportunity to assert the claim and is not substantially related to the state's interest in avoiding stale or fraudulent claims.
Facts:
- Cherlyn Clark gave birth to her daughter, Tiffany, out of wedlock on June 11, 1973.
- Clark identified Gene Jeter as Tiffany's father.
- At the time, Pennsylvania law required that a suit to establish paternity for an illegitimate child be brought within six years of the child's birth.
- In contrast, Pennsylvania law allowed a legitimate child to seek support from his or her parents at any time.
- On September 22, 1983, when Tiffany was ten years old, Clark filed a support complaint against Jeter on Tiffany's behalf.
- A court-ordered blood test indicated a 99.3% probability that Jeter was Tiffany's father.
Procedural Posture:
- Cherlyn Clark filed a support complaint against Gene Jeter in the Allegheny County Court of Common Pleas (a state trial court).
- Jeter moved to dismiss the complaint, asserting it was barred by Pennsylvania's 6-year statute of limitations for paternity actions.
- The trial court granted Jeter's motion to dismiss, and judgment was entered for Jeter.
- Clark, as appellant, appealed the dismissal to the Superior Court of Pennsylvania (an intermediate appellate court).
- The Superior Court affirmed the trial court's judgment, holding the 6-year statute of limitations was constitutional.
- Clark's petition for allowance of appeal to the Pennsylvania Supreme Court (the state's highest court) was denied.
- The United States Supreme Court granted Clark's petition for a writ of certiorari.
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Issue:
Does a six-year statute of limitations for paternity actions brought on behalf of illegitimate children violate the Equal Protection Clause of the Fourteenth Amendment when legitimate children may seek support from their parents at any time?
Opinions:
Majority - Justice O’Connor
Yes, the six-year statute of limitations violates the Equal Protection Clause. Under intermediate scrutiny, a statutory classification based on illegitimacy must be substantially related to an important governmental objective. The Court found that Pennsylvania's 6-year statute of limitations was not substantially related to its interest in avoiding the litigation of stale or fraudulent claims. The Court reasoned that Pennsylvania permitted the issue of paternity to be litigated in other contexts long after six years, such as in intestacy proceedings or in actions brought by a father to establish paternity. Furthermore, the state had recently tolled most other civil actions during a child's minority and had enacted an 18-year statute of limitations for paternity actions, undermining its own argument that a shorter period was necessary. Finally, the Court noted that advances in scientific evidence, such as genetic marker testing, have substantially alleviated the problems of proof in paternity actions, making a short limitations period less justifiable.
Analysis:
This decision solidifies the Court's application of intermediate scrutiny to statutes of limitations that differentiate between legitimate and illegitimate children. By striking down a six-year limit, the Court extended its holdings in Mills v. Habluetzel (1-year limit) and Pickett v. Brown (2-year limit), signaling that any period significantly shorter than the age of majority is constitutionally suspect. The opinion heavily relies on the availability of scientific evidence to rebut the state's interest in preventing fraudulent claims, effectively raising the bar for states seeking to justify shorter limitations periods. This case has influenced states to adopt much longer statutes of limitations, often extending to the child's 18th birthday, to comply with both constitutional standards and federal funding requirements.
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