Reed v. Reed
The Court struck down an Idaho law that automatically preferred men over women when two people were otherwise equally entitled to administer a deceased person's estate.
The ruling marked the first time the Supreme Court used the Fourteenth Amendment's equal protection guarantee to invalidate a law that treated men and women differently, opening the door to later rulings against sex-based government classifications.
How it got here: The probate court and Idaho Supreme Court favored the father under state law; Sally Reed appealed to the U.S. Supreme Court after losing below.
The Case in Depth
What happened
When Richard Reed died without a will, his separated adoptive parents, Sally and Cecil Reed, each asked an Idaho probate court to be named administrator of his small estate. Idaho law placed parents in the same entitlement class, but a separate provision said that when equally entitled people of different sexes applied, the male had to be chosen. The probate court appointed the father based on that rule.
The question before the Court
Could Idaho automatically favor a father over an equally qualified mother when both sought to administer their deceased son's estate?
Why it matters
Families settling estates in Idaho could no longer have a woman's application automatically rejected simply because a male relative also applied. More broadly, the decision gave courts a tool to strike down other laws that sorted people by sex without a legitimate reason connected to what the law was trying to achieve.
What changes now
The case was sent back to Idaho courts, which would need to decide who should administer the estate without relying on the invalidated automatic sex preference. Idaho had already adopted a new probate code, set to take effect the following year, that dropped the mandatory male preference. The decision itself was final on the constitutional question, establishing that sex-based classifications need a real justification tied to the law's purpose.
What this does not decide
The Court did not adopt a heightened or "strict" standard for sex-based classifications generally; it applied ordinary rational-relationship review and found the specific automatic preference failed even that standard. It also left undisturbed a separate provision favoring brothers over sisters in a different entitlement class, which was not challenged.
How the Court got there
The legal reasoning, step by step
- The Court applied ordinary equal protection review, asking whether a classification rests on a ground of difference with a fair and substantial relation to the law's purpose, so that people similarly situated are treated alike.
- The Court identified the actual class at issue: within the same entitlement category under the estate law (here, parents), the sex-preference rule treated otherwise identical applicants differently based solely on sex.
- The Court accepted that reducing probate courts' workload by avoiding contested hearings was a legitimate goal, but asked whether picking one sex automatically, rather than evaluating individual qualifications, was a reasonable way to reach that goal.
- The Court concluded that using sex alone as an automatic tie-breaker between equally entitled applicants was an arbitrary legislative choice, because it bore no relation to which applicant would actually administer the estate better.
- Because persons within the same entitlement class are similarly situated regardless of sex, giving one sex automatic preference over the other violated the equal protection guarantee.
Doctrinal impact
Cases affected by this decision
Reaffirms Royster Guano Co. v. Virginia (253 U.S. 412)
The Court relied on this case's standard requiring classifications to be reasonably related to a law's purpose.