Department of Mental Hygiene of Cal. v. Kirchner

Background

Mrs. Auguste Schaeche was found incompetent and confined in a California state mental institution. California law said close relatives or their estates must pay for the inmate’s care. The State institution sought about $7,554 from the estate of Mrs. Schaeche’s daughter, who had died; the claim was rejected and the California Supreme Court later struck down the statute as violating equal protection, but did not say whether it relied on the State or Federal Constitution.

Reasoning

The Court’s key question was whether it had authority to review the California decision, given the state court’s failure to identify the constitutional basis. Under long-standing rules, the U.S. Supreme Court can review a state court only when the state court’s decision rests on federal law or clearly interprets the state law under the compulsion of federal law. Because the California opinion was ambiguous about which constitution it relied on, the Justices could not say with assuredness that a federal question controlled. For that reason the Court vacated the state-court judgment and sent the case back to the California Supreme Court for clarification, following established practice.

Real world impact

The ruling does not decide whether family-support statutes are constitutional. Instead it pauses a final federal ruling and asks the California court to say whether its decision rested on state law alone. The opinion notes that many jurisdictions have similar statutes and that the issue has wide interest, so the eventual clarification could affect other cases and possibly a renewed petition to this Court.

Dissents or concurrances

Justice Douglas would have dismissed the case outright, believing the California court clearly relied on state constitutional grounds.