Reed v. Campbell

Background

A woman whose father, Prince Ricker, died intestate in December 1976 claimed a one-sixth share of his estate. Texas law then said estates descend to children, but another statute barred a child born out of wedlock from inheriting from her father unless the parents later married. A jury found that Ricker was her father, but Texas courts denied her claim because an earlier Supreme Court case striking down such total disinheritance was decided after Ricker’s death and the state court said that decision did not apply to her case.

Reasoning

The main question was whether the prior Supreme Court ruling invalidating laws that disinherited children born out of wedlock must be applied to this woman’s claim. The Court explained that the State cannot justify unequal treatment of such children merely to punish parents. It accepted that orderly estate administration can justify some timing rules, but found no adequate reason to deny her claim here. Because the estate administration was still open and the law had been declared invalid before the court decided her claim, the equal-treatment interest should control and she should be allowed to inherit.

Real world impact

The Court reversed the Texas Court of Appeals and sent the case back for further proceedings consistent with applying the earlier ruling. Practically, this means that where an estate is still being administered, people born out of wedlock cannot be denied inheritance rights simply because their parent died before a constitutional ruling came down. This decision enforces equal treatment for such children in probate proceedings.