Lalli v. Lalli

Brief Fact Summary.

The appellant challenged the New York’s Estates, Powers and Trusts Law that requires illegitimate children who would inherit from their fathers by intestate succession to provide a particular form of proof of paternity whereas legitimate children are not subject to the same requirement.

Synopsis of Rule of Law.

Classifications based on illegitimacy are not subject to strict scrutiny, but they are invalid under the Fourteenth Amendment if they are not substantially related to permissible state interests.

Facts.

Appellant Robert Lalli claims to be the illegitimate son of Mario Lalli who passed away intestate in the State of New York. Appellant’s mother, who died before her husband, never was married to Mario. Appellant claimed that he was entitled to inherit from Mario as his child although he had not complied with the New York’s law that requires illegitimate children who would inherit from their fathers by intestate succession to provide a particular form of proof of paternity. Appellant conceded that he had not obtained an order of filiation during his putative father’s lifetime. But he showed evidence of his relationship with Mario Lalli, including a notorized document in which Lalli referred to him as “my son.”

Issue.

Does the New York’s Estates, Powers and Trusts Law that requires illegitimate children who would inherit from their fathers by intestate succession to provide a particular form of proof of paternity while not requiring legitimate children the same thing violate the Constitution?

Held.

No, the New York’s Estates, Powers and Trusts Law that requires illegitimate children who would inherit from their fathers by intestate succession to provide a particular form of proof of paternity while not requiring legitimate children the same thing violate the Constitution. This is because the requirement imposed by the New York statute is substantially related to the important state interests the statute is intended to promote. Thus, it does not violate the Equal Protection Clause.

Dissent.

Justice Brennan

All interested parties concede that Robert Lalli is the son of Mario Lalli, who supported Robert during his son’s youth. Mario Lalli formally acknowledged that Robert Lalli as his son. However, due to the lack of a judicial order of filiation entered during Mario’s lifetime, Robert Lalli is denied his intestate share of his father’s estate. The fear that unknown illegitimates might assert belated claims hardly justifies cutting off the rights of known illegitimates such as Robert Lalli.

Discussion.

The New York courts have interpreted the statute liberally and in such a way as to enhance its utility to both father and child without sacrificing its strength as a procedural prophylactic. For instance, a father of illegitimate children who is willing to acknowledge paternity can waive his defenses in a paternity proceeding. As the history of the statute in question clearly illustrates, the New York Legislature desired to grant to illegitimates in so far as practicable rights of inheritance on a par with those enjoyed by legitimate children, while protecting the important state interests. The statute represents a carefully considered legislative judgment as to how this balance best could be achieved. Moreover, the statute does not effect a total statutory disinheritance of children born out of wedlock who were not legitimated by the subsequent marriage of their parents. Inheritance is barred only where there has been a failure to secure evidence of paternity during the father’s lifetime in the manner prescribed by the State. This is not a requirement that inevitably disqualifies as unnecessarily large number of children born out of wedlock.