Clark v. Jeter

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Clark v. Jeter
Court Supreme Court of the United States
Citation
Date decided June 6, 1988
Appealed from Pennsylvania Supreme Court

Facts

In the 1980s, Pennsylvania had a 6-year statute of limitations for paternity actions brought on behalf of illegitimate children.

Claims for child support or inheritance on behalf of legitimate children weren't barred by a time limitation.

Clark is the mother of Jeter's daughters; paternity testing established that Jeter was the father of Clark's daughter with a 99% certainty.

Procedural History

The Pennsylvania Supreme Court declined to hear the appeal from Clark.

Issues

How should intermediate scrutiny be applied to the rights of illegitimate children under the Equal Protection clause?

Arguments

What is the mother is under 18 or 21? In other words, what if the mother doesn't understand the level of financial that she can obtain for her child born out of wedlock?

Holding

The statute of limitations for 6 years on paternity actions on behalf of illegitimate children (those born out of wedlock) violates the Equal Protection rights of illegitimate children.

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