1. Mills v. Habluetzel, (1982)
2. Facts: A Texas law required that a paternity suit to identify the natural father of an illegitimate child for the purpose of obtaining child support must be brought before the child was one year old. The nominal state purpose was to prevent fraudulent claims later in life by the children.
3. Issue: Whether the law violated equal protection.
4. Holding: Yes.
5. Majority Reasoning: [Rehnquist]The support opportunity provided by the state [i.e. benefits depend on a paternity hearing] must be more than illusory. The law must bear a “substantial relationship to a legitimate state interest.” The period for ascertaining the fatherhood of the child must be sufficiently long to permit those who have an interest in the child to bring an action on their behalf despite the personal difficulties that may surround the birth of a child outside of wedlock. Also, the time limit set does not have a rational relationship to the state purpose of preventing fraudulent claims.
6. Concurrence Reasoning: [O’Connor] feared that the majority opinion might be read as approving an arbitrarily longer time limit (such as four years). Thus, she stated that the practical considerations that existed within the first year, which served to make the one year statute of limitations invalid, may also exist for longer periods, which would make them also invalid.
7. Notes: The court struck down a two-year limit on paternity suits in Clark v. Jeter. Finally, in Clark v. Jeter, Justice O’Connor stated that the “intermediate” level of scrutiny is applicable to illegitimacy [“substantially related to an important governmental objective”], and struck down a 6-year limit on bringing paternity actions because it was not “substantially related” to the state interest in avoiding the litigation of stale or fraudulent claims.
