Lalli v. Lalli,
439 U.S. 259 (1978)


Facts: Robert Lalli (P) sued the administrator (D) of the estate of Mario Lalli, who died intestate, claiming a share of the estate as the decedent's illegitimate child. P tendered a notarized statement of the decedent referring to P as his "son" and affidavits of several persons showing that the decedent had openly acknowledged P as his son. However, the surrogate's court ruled that P's claim was barred under a New York statute that allowed illegitimate children to share in intestate estates of parents only if filiation proceedings had been initiated before or within two years of birth. The New York Court of Appeals affirmed.

Issue: Is a statute that denies inheritance to unmarried children valid under the Fourteenth Amendment Equal Protection Clause? Is it constitutionally permissible to require a child to bear the burden to prove paternity under state statutes in order to inherit?

Rule: When a classification is based on legitimacy, the Court will use an intermediate level standard of review The Court will strike down the statute unless it is shown to be important to the achievement of a substantial government objective It is constitutionally permissible to require a child to bear the burden to prove paternity under state statutes in order to inherit

Holding: No. Illegitimacy classifications will be upheld if substantially related to a per-missible state interest.

Analysis: The Supreme Court affirmed the constitutionality of N.Y. Est. Powers & Trusts Law § 4-1.2 (1967), which required appellant illegitimate son to prove paternity with a judicial order of filiation issued during the life of his father in order to inherit from his father by intestate succession. Although this requirement was not imposed on legitimate children or children born out of wedlock whose parents intermarried, the statutory obstacle did not discriminate against appellant in violation of equal protection. The state's primary goal in enacting the statute was to provide for the just and orderly disposition of property at death. The court determined that this was an important state interest implicated in appellant's case, considering the peculiar problems of proof that were involved in establishing paternity. The means employed by the state were substantially related to the important state interest where the judicial order of filiation issued during the life of the father promoted accurate resolution of paternity disputes and minimized disruption of estate administration.