Stanton v. Stanton

Supreme Court of the United States
95 S. Ct. 1373, 1975 U.S. LEXIS 54, 421 U.S. 7 (1975)

ELI5:

Sections

Rule of Law:

A state statute specifying a greater age of majority for males than for females constitutes a gender-based classification that violates the Equal Protection Clause of the Fourteenth Amendment because it bears no fair and substantial relationship to the object of the legislation.

Facts:

Thelma Stanton and James Stanton married in 1951 and divorced in Utah in 1960.
The divorce decree incorporated a stipulation requiring James to pay monthly child support for their daughter, Sherri, and their son, Rick.
At the time, Utah Code § 15-2-1 defined the period of minority as extending to age 21 for males but only to age 18 for females.
When the daughter, Sherri, turned 18 in 1971, James discontinued her child support payments.
Thelma asserted that James was obligated to continue support for Sherri until she reached age 21, the same age of majority applied to the son.

Procedural Posture:

Thelma Stanton filed a motion in the District Court of Salt Lake County seeking judgment for past-due support payments.
The District Court denied the motion, ruling that the father's obligation ended when the daughter turned 18 pursuant to the state age-of-majority statute.
Thelma appealed to the Supreme Court of Utah.
The Supreme Court of Utah affirmed the lower court's decision, holding that the statute had a reasonable basis.
The Supreme Court of the United States noted probable jurisdiction to review the case.

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Issue:

Does a state statute that establishes the age of majority for males at 21 and for females at 18 violate the Equal Protection Clause of the Fourteenth Amendment when applied to a parent's child support obligation?

Opinions:

Majority - Justice Blackmun

Yes, the gender-based distinction in the age of majority statute is unconstitutional. Applying the standard set forth in Reed v. Reed, a classification must be reasonable and rest upon some ground of difference having a fair and substantial relation to the legislative objective. The state's justifications—that men need more education to provide for families and that women mature and marry earlier—are based on 'old notions' that are no longer valid. Women are increasingly present in the marketplace and higher education, making the need for parental support equal for both sexes. Furthermore, distinguishing based on maturity is inconsistent because the statute allows minority to be lost immediately upon marriage for either sex. Therefore, under any equal protection test, distinguishing child support obligations based solely on the sex of the child is invalid.

Dissent - Justice Rehnquist

No, the Court should not have decided the constitutional issue because the case likely rests on the interpretation of a private contract rather than state law. The support obligation arose from a voluntary settlement agreement where the parties failed to specify a termination age. The state court may have simply used the statute to interpret the parties' intent or fill a gap in the contract. Additionally, Utah has a separate support statute that defines a 'child' as anyone under 21 regardless of sex, meaning the daughter might have had a remedy under that law. Because the constitutional question was presented in an abstract form and potentially unnecessary to resolve the dispute, the appeal should have been dismissed.

Analysis:

Stanton v. Stanton is a significant decision in the evolution of gender equality jurisprudence, reinforcing the principle that state laws cannot rely on outdated gender stereotypes to justify differential treatment. By striking down the different ages of majority, the Court rejected the 'breadwinner/homemaker' dichotomy as a valid basis for legislation. This case forced states to equalize the age of majority, generally setting it at 18 for both sexes. It serves as a precursor to the 'intermediate scrutiny' standard formally adopted later in Craig v. Boren, demonstrating the Court's increasing skepticism toward sex-based classifications.

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