Curtis v. Kline

Supreme Court of Pennsylvania · 1995 · Family Law

Family LawEqual ProtectionPost-secondary educational supportChild supportFourteenth Amendmentequal protectionrational basiscollege support

Facts

The father was under a 1991 court order to support his children. In 1993 he petitioned to terminate support for two children, Amber and Jason, who were attending Kutztown University and West Chester University. After Act 62 authorized courts to order separated, divorced, unmarried, or otherwise support-obligated parents to contribute to their children's educational costs, the father amended his petition to challenge the statute's constitutionality. The facts relevant to the constitutional issue were undisputed.

Issue

Does Act 62 of 1993, which authorizes courts to order only separated, divorced, unmarried, or otherwise support-obligated parents to pay post-secondary educational costs for their children, violate the Equal Protection Clause of the Fourteenth Amendment by treating similarly situated young adults differently based on their parents' marital status?

Rule

When a statutory classification implicates neither a suspect class nor a fundamental or important right, it is reviewed under rational basis scrutiny. Under that review, the court asks first whether the statute promotes a legitimate state interest and second whether the classification is reasonably related to that interest; a classification must rest on a real and genuine distinction and have a fair and substantial relationship to the legislation's object, not merely assume the validity of the classification itself.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Pennsylvania, a statute authorizes courts to order only divorced, separated, or never-married parents to pay a share of their adult children's trade-school tuition. Nora Feldman, age 19, lives in Pittsburgh and seeks support from her divorced father, while her friend Eli Mercer in Erie cannot seek similar support because his parents remain married.

If Eli challenges the statute under the Fourteenth Amendment, what standard of review should a court apply under the majority's approach?

Explanation. The majority held that post-secondary education is neither a fundamental nor an important right for this purpose, and the statute does not involve a suspect class. Therefore the classification is reviewed under rational basis scrutiny, not heightened or strict scrutiny.