Clark v. Jeter
Annotate this Case
486 U.S. 456 (1988)
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U.S. Supreme Court
Clark v. Jeter, 486 U.S. 456 (1988)
Clark v. Jeter
Argued April 19, 1988
Decided June 6, 1988
486 U.S. 456
Ten years after her illegitimate daughter's birth, petitioner filed a support complaint on the daughter's behalf in Pennsylvania state court, naming respondent as the father. Although a blood test showed a 99.3% probability that respondent was the father, the court entered judgment for respondent on the basis of a state statute providing that actions to establish the paternity of an illegitimate child ordinarily must be commenced within six years of the child's birth. The court rejected petitioner's contentions that the statute violates the Equal Protection and Due Process Clauses of the Fourteenth Amendment to the Federal Constitution. While petitioner's appeal to the Superior Court of Pennsylvania was pending, the State adopted an 18-year statute of limitations for paternity actions, in order to comply with a requirement of the federal Child Support Enforcement Amendments of 1984 (federal Act). The Superior Court concluded, however, that the new 18-year statute of limitations did not apply retroactively, and that the 6-year period would continue to apply in cases like petitioner's. The court affirmed the trial court's conclusion that the 6-year statute of limitations was constitutional.
1. Petitioner's contention that the 6-year statute of limitations is invalid because it conflicts with an asserted retroactivity requirement in the federal Act will not be addressed by this Court, since the question of federal preemption was not adequately presented to the Superior Court by petitioner's state law retroactivity argument, and was not decided by that court. Pp. 486 U. S. 459-460.
2. The 6-year statute of limitations violates the Equal Protection Clause. Under the heightened scrutiny analysis used in evaluating equal protection challenges to statutes of limitations that apply to illegitimate children's paternity suits, the period for obtaining support must be sufficiently long to present a reasonable opportunity for those with an interest in illegitimate children to assert claims on their behalf, and any time limitation placed on that opportunity must be substantially related to the State's interest in avoiding the litigation of stale or fraudulent claims. Mills v. Habluetzel, 456 U. S. 91; Pickett v. Brown, 462 U. S. 1. Under this analysis, it is questionable whether Pennsylvania's 6-year period is reasonable, since a mother may for years after her child's birth be unwilling to assert a claim due to her relationship with the natural father, the emotional strain of having an illegitimate child, or the
desire to avoid community and family disapproval; since such a mother might realize only belatedly a loss of income attributable to the need to care for the child; and since financial difficulties are likely to increase as the child matures and incurs additional expenses. Moreover, that the 6-year period is not substantially related to an interest in avoiding the litigation of stale or fraudulent claims is established by a number of Pennsylvania statutes, including the 18-year statute of limitations, that permit paternity to be litigated more than six years after an illegitimate child's birth; and by the fact that increasingly sophisticated scientific tests facilitate the establishing of paternity regardless of the child's age. Pp. 486 U. S. 460-465.
358 Pa.Super. 550, 518 A.2d 276, reversed and remanded.
O'CONNOR, J., delivered the opinion for a unanimous Court.