County of San Luis Obispo v. Nathaniel J.
50 Cal. App. 4th 842 (1996)
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Rule of Law:
A minor father's legal obligation to provide child support is not excused by the fact that he is the victim of statutory rape, as the state's interest in ensuring a child's right to support from both parents overrides the policy of protecting a willing minor participant from the financial consequences of their actions.
Facts:
- Nathaniel J., a 15-year-old boy, and Ricci Jones, a 34-year-old woman, engaged in a consensual sexual relationship.
- Nathaniel J. described the sexual intercourse, which occurred approximately five times over two weeks, as a "mutually agreeable act."
- As a result of their relationship, Jones became pregnant and gave birth to a daughter on January 20, 1995.
- Following the birth, Jones applied for and received public assistance through Aid to Families with Dependent Children.
- Police investigated Jones's conduct, and the county prosecutor successfully prosecuted and convicted her of unlawful sexual intercourse with a minor.
Procedural Posture:
- The San Luis Obispo County District Attorney's office initiated an action in the trial court to establish paternity and obtain child support and welfare reimbursement from Nathaniel J.
- Nathaniel J., represented by a guardian ad litem, admitted paternity but contended he was not required to pay child support.
- The trial court entered a judgment establishing paternity and reserved a future order for child support.
- Nathaniel J. (appellant) appealed the trial court's judgment to the California Court of Appeal.
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Issue:
Is a minor father, who is the victim of statutory rape, obligated to pay child support for a child conceived from that act?
Opinions:
Majority - Gilbert, J.
Yes, a minor father who is the victim of statutory rape is obligated to pay child support. The court reasoned that under California law, every child has a right to support from both parents, who share an "equal responsibility." The court distinguished Nathaniel J. from an innocent victim because he willingly participated in the sexual acts. Citing precedents from other states, the court held that the state's paramount interest in requiring parents to support their children overrides the competing public policy of protecting minors from the consequences of their improvident acts, especially when the minor was a willing participant.
Analysis:
This decision solidifies the principle that the obligation of child support is based on parentage, not on the criminal or non-criminal nature of the conception. It establishes that in California, the public policy ensuring a child's right to support from both biological parents outweighs the policy of protecting a minor from the economic repercussions of statutory rape, particularly when the minor's participation was consensual. This precedent makes it difficult for a parent to use the criminal status of the other parent as a shield against their own support obligations, thereby reinforcing the state's interest in preventing children from becoming public charges.
