Reed v. Reed

Reed v. Reed was a landmark decision by the Supreme Court of the United States that marked the first time the Court struck down a state law for discriminating on the basis of sex. The unanimous ruling, delivered by Chief Justice Warren E. Burger, held that an Idaho probate statute that automatically preferred men over women as administrators of estates violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. This decision established that arbitrary gender-based classifications were subject to judicial scrutiny under the Constitution of the United States, paving the way for a new era of gender equality litigation.

Background

The case originated from a dispute over the administration of the estate of Richard Lynn Reed, a minor who died intestate in Ada County, Idaho. Both of his separated parents, Cecil Reed and Sally Reed, petitioned the Ada County Probate Court to be appointed administrator. The court was required to follow Idaho Code § 15-314, which stated that when persons of the same entitlement class (such as parents) applied, "males must be preferred to females." Citing this statute, the probate judge appointed Cecil Reed. Sally Reed, represented by future Supreme Court Justice Ruth Bader Ginsburg (then a lawyer with the ACLU's Women's Rights Project), appealed. The Supreme Court of Idaho upheld the statute, finding the legislature's intent to avoid intra-family controversy and simplify probate proceedings was a rational basis for the classification. The case was then appealed to the Supreme Court of the United States.

Supreme Court decision

In a unanimous opinion authored by Chief Justice Warren E. Burger, the Court reversed the Idaho Supreme Court. The Court applied the traditional rational basis review standard under the Equal Protection Clause but concluded the statute failed to meet it. The Court held that the objective of reducing judicial workload by eliminating hearings on the merits between competing applicants was legitimate, but the automatic preference for males was not a reasonable means to achieve it. The Court stated that giving a mandatory preference to members of either sex over the other, "merely to accomplish the elimination of hearings on the merits, is to make the very kind of arbitrary legislative choice forbidden by the Equal Protection Clause of the Fourteenth Amendment." This rejection of an overtly gender-based classification as "arbitrary" was a significant departure from prior precedent.

Significance and impact

The decision in this case was a watershed moment for women's rights in the United States. It was the first time the Supreme Court of the United States invalidated a state law on the grounds of sex discrimination, signaling a new judicial willingness to examine gender-based classifications. While the Court used rational basis review, its application was notably stricter, often termed "rational basis with bite." The victory provided crucial momentum for the ACLU's Women's Rights Project and its litigator Ruth Bader Ginsburg, who would go on to argue and win several more pivotal cases, including Frontiero v. Richardson and Craig v. Boren. The ruling directly challenged the legal fiction of women's inherent inferiority that had underpinned many state laws.

Subsequent developments

The precedent set by this case served as the foundation for a series of decisions that heightened the level of scrutiny applied to sex-based classifications. In Frontiero v. Richardson (1973), a plurality of justices advocated for applying strict scrutiny, the standard used for race-based classifications. While the Court did not formally adopt that standard, it established an intermediate level of scrutiny in Craig v. Boren (1976), requiring such classifications to serve important governmental objectives and be substantially related to those objectives. This intermediate scrutiny standard became the governing test for evaluating the constitutionality of sex-based laws. The legal principles established in this case also influenced rulings on discrimination against men, as seen in cases like Stanley v. Illinois, and contributed to the jurisprudence that would later address laws affecting LGBT rights in the United States, such as United States v. Virginia.

Category:United States Supreme Court cases Category:United States equal protection case law Category:1971 in United States case law