Clark v. Jeter

Background

Cherlyn Clark, a mother, filed a support suit in 1983 on behalf of her daughter Tiffany, who was born out of wedlock in 1973, naming Gene Jeter as the father. Blood tests showed a 99.3% probability that Jeter was the father. Pennsylvania law then required most illegitimate children to sue to establish paternity within six years of birth. The trial court dismissed Clark’s complaint as time-barred; the state superior court affirmed, and Pennsylvania later enacted an 18-year limit but the courts held it was not retroactive. Clark argued the six-year limit violated the federal Constitution.

Reasoning

The Court examined whether the six-year deadline was fair under the Equal Protection Clause. Applying the established framework for paternity statutes, it asked whether six years gave a reasonable opportunity to bring claims and whether the deadline was substantially related to preventing stale or fraudulent suits. The Court found six years could be too short for many mothers who face emotional, financial, or social obstacles, and that Pennsylvania’s own laws and practices undercut its interest in preventing stale claims. The state allowed paternity to be litigated in several circumstances after six years, had tolling rules during minority, and later adopted an 18-year limit. Advances in blood testing also reduced proof concerns. For these reasons, the Court held the six-year limit failed heightened scrutiny. The Court did not reach Clark’s separate due process claim and declined to decide a federal preemption argument that was not adequately raised below.

Real world impact

The ruling means mothers and children born out of wedlock in Pennsylvania have more opportunity to pursue paternity and child-support claims, and some previously time-barred claims may proceed on remand.