Curtis v. Kline

Citation. Curtis v. Kline (appeal of Dep’t of Pub. Welfare), 542 Pa. 249, 666 A.2d 265, 1995 Pa. LEXIS 925 (Pa. Oct. 10, 1995)

Brief Fact Summary. Appellee challenged the constitutionality of an Act which allowed a court to order separated, divorced, or unmarried parents to provide equitably for educational costs of a child, even after the child has reached 18.

Synopsis of Rule of Law. The Act violates the equal protection clause of the Fourteenth Amendment because it is not rationally related to a legitimate state interest.

Facts. Appellee filed a petition to terminate his child support obligations two his two children who were attending college. Act 62 was promulgated, which allowed a court to order separated, divorced, or unmarried parents to provide equitably for educational costs of a child, even after the child has reached 18. After inaction of Act 62, appellee was granted leave to include a constitutional challenge to the Act as a basis for seeking relief from post-secondary educational support.

Issue. Does Act 62 violate the equal protection clause of the Fourteenth Amendment of the United States Constitution?

Held. The Act violates the Constitution because there is no rational basis for applying the authority of the state selectively to empower only those from non-intact families to compel support for post-secondary educational support.
The Act neither implicates a suspect class nor infringes upon a fundamental right, therefore it must be upheld if there exists any rational basis for the prescribed classification. The Act classifies young adults according to the marital status of their parents.

Under the Act a parent with a child born to a second marriage would be required to provide such support for the first child but not the second. This demonstrates the arbitrariness of the Act. Other States have found the underlying premise is to address the unique problems of divorced families. However, this Court rejects such analysis because the Act is focused not on the parents but the children.

Dissent. The Act operates on an assumption that divorce involves a disadvantage to the children of broken families, and assures that such children are not deprived, but are put in the same position as if the marriage had remained intact. Divorced parents too frequently become reluctant to provide financial support for any purpose, and the Act is rationally related to equalizing the disparate situation faced by children of divorce.

Discussion. The majority found that the Act had no rational relation to a legitimate state interest because it benefited children of divorce while not providing for other children. The dissent and other states have found such Acts rational in that children of divorce are disproportionately disadvantaged.