Moe v. Dinkins
1981 U.S. Dist. LEXIS 13974, 533 F. Supp. 623 (1981)
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Rule of Law:
A state law requiring parental consent for the marriage of minors does not violate the Due Process Clause of the Fourteenth Amendment because it is rationally related to the state's legitimate interests in protecting minors from immature decision-making and preventing unstable marriages.
Facts:
- Plaintiff Maria Moe, age fifteen, and plaintiff Raoul Roe, age eighteen, had a one-year-old son, Ricardo Roe, and lived together as an independent family.
- Maria requested consent from her widowed mother to marry Raoul, but her mother refused, allegedly because she wished to continue receiving welfare benefits for Maria.
- Cristina Coe, age fifteen, became pregnant by her partner, Pedro Doe, age seventeen.
- Cristina and Pedro informed Cristina's mother of their desire to marry, but her mother refused consent, arranged for an abortion which Cristina refused, and then told Cristina she wanted nothing more to do with her.
- Both couples wished to marry to cement their family units and remove the stigma of illegitimacy from their children.
- The couples were prevented from obtaining marriage licenses solely because they could not obtain the parental consent required by New York's Domestic Relations Law § 15.
Procedural Posture:
- Plaintiffs filed a class-action lawsuit in the U.S. District Court for the Southern District of New York, seeking to declare New York's parental consent law for marriage unconstitutional.
- The District Court initially abstained from deciding the case, pending interpretation by New York state courts.
- Plaintiffs appealed to the U.S. Court of Appeals for the Second Circuit, which reversed the abstention order and remanded the case back to the District Court for a decision on the merits.
- Upon remand to the District Court, plaintiffs filed a motion for summary judgment.
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Issue:
Does a New York statute requiring minors between the ages of fourteen and eighteen to obtain parental consent to receive a marriage license violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Motley, District Judge.
No, the parental consent requirement of Section 15 does not violate the plaintiffs' constitutional rights. While the right to marry is a fundamental right for adults, the constitutional rights of children are not coextensive with those of adults due to their vulnerability, inability to make mature decisions, and the importance of the parental role. Therefore, the state law is subject to rational basis review, not strict scrutiny. The state possesses legitimate interests under its parens patriae power to protect minors from immature decision-making and to prevent unstable marriages. Requiring parental consent is rationally related to these interests because it ensures a mature person participates in the minor's decision. Unlike the irretrievable decision to carry a pregnancy to term, the denial of a marriage license is merely a temporary delay that postpones the decision until the minor reaches the age of majority.
Analysis:
This decision affirms the state's significant authority to regulate the activities of minors, even when a fundamental right like marriage is involved. By applying rational basis review instead of strict scrutiny, the court established a lower bar for justifying such regulations, distinguishing the right to marry from reproductive rights which receive greater protection for minors. This case reinforces the legal presumption of parental authority and differentiates between a temporary 'delay' of a right (marriage) and an 'irretrievable' deprivation of a right (abortion), a distinction that has influenced subsequent cases concerning minors' rights.
