Lalli v. Lalli

Brief Fact Summary. The Appellant, Robert Lalli (Appellant), seeking inheritance from his father, challenges the constitutionality of a New York statute requiring him to prove paternity, before the death of his father.

Synopsis of Rule of Law. State laws classifying children on legitimacy must be substantially related to the important state interest the statute is intended to promote.

Facts. The Appellant claimed to be the illegitimate son of Mario Lalli who died intestate. The Appellant argued that he was entitled to inherit from father and that the New York statute, requiring him to obtain an order of filiation during his father’s lifetime, discriminated against him on the basis of his illegitimate birth in violation of the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution (Constitution). A New York trial and appellate court ruled against the Appellant. The judgment of the appellate court is affirmed.

Issue. Whether the New York law requiring illegitimate children to provide a particular form of proof of paternity, in order to inherit from their fathers, is unconstitutional.

Held. No. The New York requirement for illegitimate children who would inherit from their fathers is substantially related to the important state interests that the statute intended to promote. The judgment of the Court of Appeals is affirmed.
The main goal of the statute “is to provide for just and orderly disposition of property at death.” This goal has been recognized as an important state interest.
Proof of paternity becomes more difficult after the father’s death. Therefore, the state also expressed an important interest in preventing “fraudulent claims of heirship and harassing litigation instituted by those seeking to establish themselves as illegitimate heirs.”

Dissent. Justice William Brennan (J. Brennan). The New York statute discriminates against illegitimate children “through means not substantially related to the legitimate interests that the state purports to promote . . . .”
Concurrence. The concurring opinions are as follows:
Justice Potter Stewart (J. Stewart). The ruling of the Supreme Court provides “authoritative guidance to the courts and legislatures of the several States.
Justice Harry Blackmun (J. Blackmun). Trimble v. Gordon, 430 U.S. 762 (1977), should have been overruled, not distinguished, by this decision.

Discussion. The Supreme Court illustrated that paternity suits are now classified among gender discrimination cases and require intermediate scrutiny requiring that the statutory classification be substantially related to an important governmental objective.