Caseflicks

Supreme Court of the United States • 1971

Reed v. Reed

404 U.S. 71 | 92 S. Ct. 251 | 30 L. Ed. 2d 225 | 1971 U.S. LEXIS 8

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Takeaway

In short, this case established that a State may not give men an automatic legal preference over similarly situated women merely for administrative convenience.

Background

Richard Lynn Reed, a minor, died intestate in Ada County, Idaho. His adoptive parents, Sally Reed and Cecil Reed, had separated before his death. Both petitioned to administer their son's small estate: Sally sought appointment as administratrix, and Cecil filed a competing petition to be administrator.

Under Idaho Code § 15-312, a decedent's father and mother occupied the same class of persons entitled to administer the estate. But § 15-314 required that, among persons equally entitled, males be preferred to females. Without comparing the parents' individual qualifications, the probate court appointed Cecil solely because he was male.

Sally appealed. The Idaho district court held the male-preference provision unconstitutional under the Equal Protection Clause and ordered the probate court to determine which parent was better qualified. The Idaho Supreme Court reversed, holding that the statutory preference for men was mandatory and constitutionally valid because it spared probate courts the need to decide competing applicants' relative merits. The U.S. Supreme Court reversed the Idaho Supreme Court.

Issues

Issue #1

Whether Idaho may require probate courts to prefer a male over a female when equally entitled parents seek appointment to administer their child's intestate estate.

Holding

No. Idaho's mandatory preference for males over equally entitled females violates the Equal Protection Clause of the Fourteenth Amendment.

Reasoning

Section 15-314 expressly classified applicants by sex. Although Idaho did not categorically bar women from administering estates, the statute required different treatment when a male and female within the same entitlement class competed for appointment. That sex-based distinction was therefore subject to Equal Protection Clause review.

The Equal Protection Clause permits States to create classifications and treat different groups differently, but a classification must be reasonable rather than arbitrary. It must rest on a difference that has a fair and substantial relation to the statute's objective, so that people similarly situated in relation to that objective receive like treatment.

Idaho's asserted objective—reducing probate-court workload by avoiding hearings over which equally entitled relative is more qualified—was legitimate. But a mandatory preference for men was not a constitutionally permissible means of advancing that objective. The State could not eliminate an individualized merits hearing simply by automatically selecting one sex over the other.

The result did not change if § 15-314 was understood as supplementing § 15-312's system of ordering relatives by their relationship to the decedent. Within the same class under § 15-312, a father and mother were similarly situated for purposes of entitlement to administer the estate. Treating them differently solely because one was male and the other female lacked the required relation to that statutory objective.