Mills v. Habluetzel

Background

The case was brought by a mother on behalf of her child born out of wedlock and the Texas Department of Human Resources, which had been assigned the child's support claim. Texas law at the time required that a suit to establish paternity be brought before the child turned one year old. The trial court and Texas courts held the suit time-barred, and the Supreme Court agreed to decide whether that one-year limit was constitutional.

Reasoning

The Court asked whether a one‑year window gives illegitimate children a real opportunity to establish paternity and obtain support and whether that short limit is substantially related to the State's interest in avoiding stale or fraudulent claims. The majority said the one‑year limit is too short. It noted common obstacles an unwed mother may face in the child's first year and the special proof problems in paternity cases. Because the one‑year rule effectively extinguished the child's right to seek paternal support, the Court found it violated the Equal Protection Clause and reversed the Texas court.

Real world impact

The decision removes the one‑year bar as applied and sends the case back for further proceedings consistent with the opinion. It requires Texas to afford illegitimate children a bona fide chance to pursue support. The Court recognized that time limits to prevent stale claims can be legitimate, but the limit must be long enough to be meaningful.

Dissents or concurrances

Justice O'Connor, joined by others, warned that the opinion should not be read as approving Texas's later four‑year amendment and cautioned that longer limits may also raise constitutional concerns.