Matter of Marriage of Crocker
157 Or. App. 651, 1998 Ore. App. LEXIS 2246, 971 P.2d 469 (1998)
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Rule of Law:
A state statute that authorizes courts to order divorced or separated parents to pay for the post-secondary education of their children between ages 18 and 21, while not imposing the same obligation on married parents living together, does not violate the Equal Protection Clauses of the state or federal constitutions because the classification is rationally related to a legitimate state interest.
Facts:
- Mother and Father divorced in 1987 when their three daughters were minors.
- The initial dissolution judgment ordered Father to pay child support for each child.
- In 1995, the court modified the support order to include support for the parties' oldest daughter, who was over 18 and attending school.
- In 1997, the parties' second daughter turned 18 and planned to attend college in California.
- Mother sought another modification of the child support order to require Father to provide support for the second daughter while she attended college.
Procedural Posture:
- Mother filed a motion in the trial court to modify Father's child support obligation.
- Father filed a motion to dismiss, arguing the authorizing statute, ORS 107.108, was unconstitutional.
- The trial court found the statute unconstitutional under the Oregon Constitution and the Fourteenth Amendment to the U.S. Constitution.
- The trial court granted Father's motion and entered a judgment dismissing Mother's motion to modify.
- Mother, the appellant, appealed the trial court's judgment to the Court of Appeals of Oregon, the state's intermediate appellate court.
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Issue:
Does an Oregon statute that authorizes courts to order divorced parents, but not married parents living together, to pay child support for their children aged 18 to 21 who are attending school violate the Equal Protection Clauses of the Oregon and United States Constitutions?
Opinions:
Majority - Armstrong, J.
No. The Oregon statute does not violate the Equal Protection Clauses of the Oregon or United States Constitutions because the distinction it draws between divorced and married parents is rationally related to a legitimate state interest. The state has a legitimate interest in having a well-educated populace, which is advanced by parental support for children attending school. The legislature could rationally believe that the breakdown of a marriage due to divorce or separation creates unique circumstances where parents, who might otherwise support their child's education, fail to do so due to acrimony, disagreement over contributions, or a changed sense of obligation. Authorizing courts to intervene in these specific situations is a rational response to a problem that is less likely to occur in intact families, where parents are presumed to make such decisions cooperatively. The statutory scheme does not need to be perfectly tailored to be constitutional; it is sufficient that the classification is a reasonable method to address a problem unique to the class of divorced or separated parents.
Analysis:
This decision reinforces the principle that classifications based on marital status are subject to rational basis review, the most deferential standard of constitutional scrutiny. The court affirmed that legislatures may treat intact families differently than families affected by divorce or separation, recognizing that the latter may require state intervention to resolve disputes that intact families are presumed to resolve privately. This case establishes a precedent in Oregon that post-majority educational support obligations can be constitutionally imposed on a select class of parents (divorced/separated) without being extended to all parents. It signals that courts will uphold family law statutes that draw such distinctions as long as the legislature can posit a rational reason for the differential treatment, even if the fit between the problem and the solution is not perfect.
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