Rivera v. Minnich
Annotate this Case
483 U.S. 574 (1987)
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U.S. Supreme Court
Rivera v. Minnich, 483 U.S. 574 (1987)
Rivera v. Minnich
Argued March 25, 1987
Decided June 25, 1987
483 U.S. 574
Appellee, an unmarried mother, filed a child support suit in a Pennsylvania court against appellant, alleging that he was the child's father. The judge denied appellant's pretrial motion seeking a ruling that the Due Process Clause of the Fourteenth Amendment was violated by a state statute providing that the burden of proving paternity "shall be by a preponderance of the evidence," and requesting a jury instruction that paternity must be established by clear and convincing evidence. Applying the preponderance standard, the jury found that appellant was the father, but the judge later reconsidered his ruling on the burden of proof issue and granted appellant's motion for a new trial. The Pennsylvania Supreme Court held that the statute was constitutional, and reinstated the jury's verdict.
Held: Pennsylvania's preponderance standard for determining paternity is constitutionally permissible. The preponderance standard is applied most frequently in litigation between private parties in every State and, more specifically, is the standard that is applied in paternity litigation in the majority of American jurisdictions that regard such proceedings as civil in nature (as does Pennsylvania). Such a legislative judgment is entitled to a powerful presumption of validity when challenged under the Due Process Clause. This case is not controlled by the holding in Santosky v. Kramer, 455 U. S. 745, that the Constitution requires clear and convincing evidence before a State may terminate the parental relationship. Appellant's contention to the contrary rests on the erroneous tacit assumption of an equivalence between the State's imposition of the legal obligations accompanying a biological relationship between parent and child and the State's termination of a fully existing parent-child relationship. The collective judgment of the many state legislatures that adhere to a preponderance standard for paternity proceedings rests on legitimate and significant distinctions between termination and paternity proceedings. Pp. 483 U. S. 577-582.
509 Pa. 588, 506 A.2d 879, affirmed.
STEVENS, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, MARSHALL, BLACKMUN, POWELL, and SCALIA, JJ., joined. O'CONNOR, J., filed an opinion concurring in the judgment, post, p. 483 U. S. 582. BRENNAN, J., filed a dissenting opinion, post, p. 483 U. S. 583.