Stanton v. Stanton

Background

A divorced father and his daughter litigated when his legal duty to support her should end under a Utah law that set age 21 for males but 18 for females. In an earlier decision this Court found that gender difference unconstitutional and sent the case back to Utah courts to decide which single age should apply. The earlier mandate also ordered the daughter be paid $437.38 in appeal costs.

Reasoning

On remand the Utah Supreme Court refused to address the equal-treatment mandate, held the female provision applied, reversed the lower court that had set age 21 for support purposes, and even denied the earlier costs award. This Court held that Utah’s actions did not follow its prior ruling. It vacated the Utah Supreme Court’s judgment and sent the matter back for further state-court proceedings consistent with the requirement that males and females be treated equally. The opinion noted Utah may choose age 18 or 21 for everyone, and mentioned the State’s 1975 legislative amendment setting age 18 for both sexes (which the parties agree does not apply to this dispute).

Real world impact

The decision affects parents and children in Utah by requiring state courts to adopt one single age that determines when child-support obligations end, without separate ages for males and females. The rule is not a final choice of age here; instead, the case must proceed in state courts to determine the correct single age under state law. The daughter’s cost award from this Court remains recognized as owing.

Dissents or concurrances

Justice Stevens, dissenting in part, argued the Utah Supreme Court’s result was largely consistent with this Court’s mandate (except for denying costs) and thought no further proceedings were necessary.