Summary of Lalli v. Lalli, 439 U.S. 259 (1978)
Facts: Mr. Lalli claimed to be the illegitimate child of an intestate father. The deceased mother never married that man, but the man had made statements that he was the child’s father.
Issue(s): Whether the NY statutory obstacles to inheritance by illegitimate children violates the E P Cl of the 14th; and if the procedural demands placed on illegitimate children bear a evident and Subst’l relation to the particular state interests it was designed to serve?
Holding: The requirements of the NY Law as imposed against illegitimate children who would inherit from their fathers is Substantially Related to the important state Int the law was intended to promote. It does not violate the EP Cl.
Procedure: Mrs. Lalli was appt’d Administratrix; child petitioned Surrogate Ct for acct’g claiming he and his sister were biological children and entitled to inherit. Ct of App held the purpose was to discourage illegitimacy, to mold human conduct, and set societal norms. USSCt Affirmed NY Ct of App Judgment.
Rationale: Previously NY law permitted illegitimate children to inherit only from their mothers, and by lifting that ban the current statute was tends to achieve the desired effect. Under NY law marital status is irrelevant. The only real issue is an evidentiary one–ct determined paternity.
INTEREST: The legislative purposes as explained by Ct of App has been confirmed, but the primary state goal is to provide for the just and orderly disposition of property at death. Thus, in this area states have a long recognized interest. The interest is directly implicated in cases involving inheritance by illegitimate children /c of the problems of proof. Proof of paternity is difficult when the father is not part of the formal family unit. The vast associative problems call for different treatment btwn illegitimate and legitimate children as heirs.
PROB: Illegitimate children, if made an unconditional distributee in testacy, must be served with process. Service would be impossible where the neither the child nor family are aware of the existence of each other. Finality of the decree could not occur. Thus, the state interest in providing for the just and orderly disposition of property at death is a subst’l state interest.
MEANS: Adminst’n of an estate can be facilitiated and the possibility of dealy, fraud, and uncertainty minimized by placing paternity disputes in a judicial forum during the lifetime of the father.
Pl’s A: (Child) Although no order was issued by Ct, the statute, by imposing the requirement, discriminated against him b/c of an immutable characteristic, illegitimacy, in violation of EP Cl. Know illegitimate children, as a significant category of illegitimate children, could inherit w/o threatening the orderly disposition by proving paternity w/o Ct order–therefore cannot be Rationally be denied inheritance b/c there are no risks the statute was designed to minimize.
Df’s A: (Adminstrix) Even if the children were the biological issue, they were not lawful distributees of the state b/c they failed to comply w/ the statutory requirements. Legitimacy is determined if either 1) Ct has, during the life of the father, made an order of filation, instituted during the mother’s pregnancy or w/i 2 years of child’s life.