Reed v. Campbell
1986 U.S. LEXIS 56, 476 U.S. 852, 90 L. Ed. 2d 858 (1986)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A new constitutional rule prohibiting discrimination against illegitimate children in matters of inheritance must be applied to an estate that has not been finally settled, even if the decedent died before the new rule was announced.
Facts:
- In November 1957, Prince Ricker and the appellant's mother participated in a ceremonial marriage that was invalid because Ricker's previous divorce was not yet final.
- The appellant was born a year later, making her an illegitimate child under Texas law at the time.
- Prince Ricker died intestate (without a will) on December 22, 1976.
- At the time of Ricker's death, Texas Probate Code § 42 completely prohibited an illegitimate child from inheriting from their father unless the parents had subsequently married.
- Ricker was survived by five legitimate children from other marriages and the appellant.
- In February 1978, while Ricker's estate was still undergoing administration and had not been finally distributed, the appellant formally asserted her claim for a one-sixth share of the estate.
Procedural Posture:
- Appellant filed a formal complaint in Texas Probate Court asserting her claim to her father's estate.
- A jury found that Prince Ricker was appellant's father, but the trial court denied her claim based on Texas Probate Code § 42.
- Appellant appealed to the Texas Court of Appeals, which affirmed the trial court's decision, holding that the Supreme Court's decision in Trimble v. Gordon did not apply retroactively.
- Appellant's application for a writ of error to the Texas Supreme Court was refused.
- The U.S. Supreme Court noted probable jurisdiction to hear the case.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Equal Protection Clause of the Fourteenth Amendment require a state to apply a new constitutional rule prohibiting the total disinheritance of illegitimate children to a claim filed after the rule was announced against a father's estate that is still open for administration, even though the father died before the rule was established?
Opinions:
Majority - Justice Stevens
Yes. The Equal Protection Clause requires that the constitutional rule announced in Trimble v. Gordon be applied to appellant's claim because the state's interest in the orderly administration of the estate is not compromised. The Court distinguished between permissible and impermissible state interests in laws concerning illegitimacy. A state may not discriminate against illegitimate children to express disapproval of their parents' conduct. While a state does have a legitimate interest in the orderly and just distribution of a decedent's property, that interest is not implicated here. The estate was still open and the claim was asserted before any final distribution occurred. Therefore, adjudicating the appellant's claim would not have disrupted the administration of the estate. Because there was no valid state interest in refusing to apply the current, constitutionally required rule of law, the interest in providing equal treatment to illegitimate children under the Fourteenth Amendment was controlling.
Analysis:
This decision clarifies the application of newly announced constitutional rules, particularly in the context of inheritance rights. The ruling establishes that the dispositive factor is not the date of the decedent's death, but the status of the estate's administration. By focusing on whether applying the new rule would disrupt the state's legitimate interest in finality and orderly administration, the Court prevents states from using arbitrary temporal cutoffs to deny constitutional rights. This holding strengthens protections for illegitimate children by ensuring that the rule from Trimble v. Gordon applies broadly to all pending matters where state interests are not genuinely threatened, reinforcing that classifications based on illegitimacy face significant scrutiny.
