Lalli v. Lalli Case Brief

Why is the case important?

The Appellant, Robert Lalli (Appellant), seeking inheritance from his father, challenges the constitutionality of a New York statute requiring him to prove paternity, before the death of his father.

Facts of the case

Question

Whether the New York law requiring illegitimate children to provide a particular form of proof of paternity, in order to inherit from their fathers, is unconstitutional.

Answer

No. The New York requirement for illegitimate children who would inherit from their fathers is substantially related to the important state interests that the statute intended to promote. The judgment of the Court of Appeals is affirmed.
The main goal of the statute is to provide for just and orderly disposition of property at death. This goal has been recognized as an important state interest.
Proof of paternity becomes more difficult after the father’s death. Therefore, the state also expressed an important interest in preventing fraudulent claims of heirship and harassing litigation instituted by those seeking to establish themselves as illegitimate heirs.

Conclusion

The Supreme Court affirmed the constitutionality of N.Y. Est. Powers & Trusts Law § 4-1.2 (1967), which required Robert to prove paternity with a judicial order of filiation issued during the lifetime of his father in order to inherit from his father by intestate succession. Although this requirement was not imposed on legitimate children or children born out of wedlock whose parents intermarried, the statutory obstacle did not discriminate against illegitimate children in violation of equal protection. The state’s primary goal in enacting the statute was to provide for the just and orderly disposition of property at death. The Court determined that this was an important state interest implicated in Robert’s case, considering the peculiar problems of proof that were involved in establishing paternity. Thus, the Court held that the means employed by the state were substantially related to the important state interest where the judicial order of filiation issued during the life of the father promoted accurate resolution of paternity disputes and minimized disruption of estate administration.

  • Case Brief: 1978
  • Appellant: Lalli
  • Appellee: Lalli
  • Decided by: Burger Court

Citation: 439 US 259 (1978)
Argued: Oct 4, 1978
Decided: Dec 11, 1978