Pickett v. Brown

Background

A mother, Frances Annette Pickett, sued to establish that Braxton Brown was the father of her son and to require him to pay child support. Tennessee law allowed paternity suits but barred most suits filed more than two years after a child’s birth, with exceptions when the father had acknowledged paternity or the child was or might become a public charge. Lower courts split: a juvenile court struck down the two‑year rule, the Tennessee Supreme Court upheld it, and the case reached the United States Supreme Court.

Reasoning

The Court considered whether the two‑year limit gave illegitimate children a reasonable chance to sue and whether the limit was meaningfully connected to preventing stale or fraudulent claims. Relying on earlier decisions, the Court held the period was too short because mothers often face financial, emotional, and social obstacles that delay filing; the limitation was not tolled during the child’s minority while Tennessee tolled many other claims; and the statute’s exception for children receiving or likely to receive public assistance undermined the State’s stated interest. Advances in blood testing also weakened the need for such a short deadline. For these reasons the Court found the two‑year limit violated the Equal Protection Clause.

Real world impact

The decision requires Tennessee courts to allow paternity and child‑support suits beyond two years in the situations the Court described and restores the ability of some illegitimate children to seek support. The case was reversed and remanded for proceedings consistent with the opinion. The ruling emphasizes that time limits cannot unduly extinguish a child’s right to support.