Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

statuteappealtrialmotiondivorceappellantappellee
liabilitystatutetrialdivorceappellantappellee

Related Cases

Rauda v. Jennings
View Case »
Kenneth McPeek Racing Stables, Inc.; U.S. v.
View Case »
Medina-Morales v. Ashcroft
View Case »
Lucio; U.S. v.
View Case »
Prekaj v. Immigration and Naturalization Service
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Stanton v. Stanton

Facts

Appellant Thelma B. Stanton and appellee James Lawrence Stanton, Jr. were divorced in Utah, and the court awarded custody of their children to the mother along with child support. When their daughter Sherri turned 18, the father stopped making support payments. The mother filed a motion to compel continued support until Sherri turned 21, arguing that the Utah statute discriminated based on sex by allowing males to be supported until age 21 while females were cut off at 18. The trial court denied her motion, leading to the appeal.

Appellant Thelma B. Stanton and appellee James Lawrence Stanton, Jr. were married at Elko, Nev, in February 1951. At the suit of the appellant, they were divorced in Utah on November 29, 1960. They have a daughter, Sherri Lyn, born in February 1953, and a son, Rick Arlund, born in January 1955. Sherri became 18 on February 12, 1971, and Rick on January 29, 1973.

Issue

Whether a state statute specifying for males a greater age of majority than it specifies for females denies, in the context of a parent's obligation for support payments for his children, the equal protection of the laws guaranteed by 1 of the Fourteenth Amendment.

This case presents the issue whether a state statute specifying for males a greater age of majority than it specifies for females denies, in the context of a parent's obligation for support payments for his children, the equal protection of the laws guaranteed by 1 of the Fourteenth Amendment.

Rule

A classification must be reasonable, not arbitrary, and must rest upon some ground of difference having a fair and substantial relation to the object of the legislation, so that all persons similarly circumstanced shall be treated alike.

A classification 'must be reasonable, not arbitrary, and must rest upon some ground of difference having a fair and substantial relation to the object of the legislation, so that all persons similarly circumstanced shall be treated alike.'

Analysis

The Court found that the distinction drawn by the Utah statute, which allowed males to be supported until age 21 while females were cut off at 18, imposed criteria wholly unrelated to the objective of the statute. The Court noted that a child, regardless of sex, is still a child and that societal roles have evolved, making the rationale for the age distinction outdated and unjustifiable.

Notwithstanding the 'old notions' to which the Utah court referred, we perceive nothing rational in the distinction drawn by 15-2-1 which, when related to the divorce decree, results in the appellee's liability for support for Sherri only to age 18 but for Rick to age 21. This imposes 'criteria wholly unrelated to the objective of that statute.'

Conclusion

The Court reversed the judgment, holding that the difference in sex between children did not warrant a distinction in obligation of support, and that the determination of when the father's obligation to support his daughter terminated was a state issue to be resolved on remand.

We therefore conclude that under any test – compelling state interest, or rational basis, or something in between – 15-2-1, in the context of child support, does not survive an equal protection attack.

Who won?

The appellant mother prevailed in the case because the Supreme Court found that the Utah statute's distinction based on sex was unconstitutional under the Equal Protection Clause.

The appellant, thus, was held not entitled to support for Sherri for the period after she attained 18, but was entitled to support for Rick 'during his minority' unless otherwise ordered by the trial court.

You must be