Stanton v. Stanton

1975-04-15

Headline: Utah rule making females adults at 18 but males at 21 struck down in child-support disputes, forcing equal treatment of sons and daughters and changing how divorce support orders are applied.

Holding: The Court held that Utah’s statute setting the age of majority at 18 for females but 21 for males violates the Fourteenth Amendment’s equal protection guarantee in child-support cases, and it reversed the Utah Supreme Court.

Real World Impact:

Requires equal parental support treatment for sons and daughters.
Family courts must revisit divorce orders and past unpaid support for ages 18–21.
State legislatures or courts decide how to set a single age of majority.

Topics: age of majority, sex discrimination, child support, divorce orders, equal protection

Summary

Background

A divorced mother and father agreed to a support order for their two children. When their daughter turned 18 the father stopped paying her support under a Utah law that defined females as adults at 18 but males at 21. The mother challenged that result after the Utah Supreme Court applied the age statute and denied support for the daughter after 18.

Reasoning

The Court asked whether a law that makes girls adults at 18 but boys at 21 treats children unequally for purposes of parental support. Relying on earlier equal-protection principles, the Court found no rational relation between sex and the need for parental support. The majority emphasized that social roles and opportunities for women have changed and that other Utah laws treat males and females alike. It concluded that the age difference, in the child-support context, violates the Fourteenth Amendment’s promise of equal protection. The Court reversed the Utah decision and sent the case back to the Utah courts to decide how to fix the result under state law.

Real world impact

Divorced parents, children, and family courts are affected: support obligations for sons and daughters must be treated the same when age of majority matters. The ruling is not a final answer about the single age to apply; state courts or legislatures must pick whether to raise the female age, lower the male age, or apply some other state-law rule. The federal decision resolves the constitutional claim but leaves implementation to Utah authorities.

Dissents or concurrances

A dissent argued the Court should not have decided the constitutional question on these facts and would have dismissed the appeal rather than reach the statute’s validity.