Rainey v. Chever
Headline: Denied review of Georgia law that blocks fathers who neglected out-of-wedlock children from inheriting, leaving a state court’s ruling striking the law on gender-based discrimination in place.
Holding: The Supreme Court declined to review Georgia’s appeal, leaving the Georgia court’s ruling that the inheritance rule treats fathers and mothers unequally under the Constitution in place.
- Leaves Georgia’s invalidation of the inheritance rule in effect.
- Puts similar state laws in multiple states into legal doubt.
- May lead to more lawsuits over parent-child inheritance disputes.
Summary
Background
The dispute involves a Georgia law that bars a father (or his paternal relatives) from inheriting from a child born out of wedlock if the father failed to treat the child as his own or failed to provide support. DeAndre Hamilton died in 1997. His biological father had little or no contact with him, yet quickly sued for damages after DeAndre’s death. DeAndre’s mother asked a court to determine heirs and relied on the Georgia statute to deny the father any inheritance.
Reasoning
The Georgia Superior Court and the Georgia Supreme Court ruled that the statute treated fathers differently from mothers and violated the Constitution’s guarantee of equal treatment. The Georgia Supreme Court applied heightened review, finding the law relied on gender-based generalizations and did not sufficiently advance the State’s interest. Justice Thomas’s dissent argues prior Supreme Court decisions treated similar laws differently and that Georgia’s law distinguishes between fathers who support children and those who do not.
Real world impact
The U.S. Supreme Court declined to review the Georgia decision, leaving the state court’s ruling in place. Because many States have enacted similar rules, the Georgia decision casts doubt on those statutes. The legal question about whether such inheritance limits are permissible or unlawful remains unsettled nationally unless the Court later changes course.
Dissents or concurrances
Justice Thomas, joined by the Chief Justice and another Justice, dissented from the denial of review and would have granted review to clarify whether these statutes are constitutional, noting conflicting lower-court approaches.
Opinions in this case:
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