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Reed v. Reed
Citations: 30 L. Ed. 2d 225; 92 S. Ct. 251; 404 U.S. 71; 1971 U.S. LEXIS 8Docket: 70-4
Court: Supreme Court of the United States; November 22, 1971; Federal Supreme Court; Federal Appellate Court
A mandatory provision of the Idaho probate code that prioritizes men over women when appointing an administrator for a decedent's estate was found to violate the Equal Protection Clause of the Fourteenth Amendment. In the case of Sally M. Reed v. Cecil R. Reed, the probate court favored the male father, Cecil Reed, over the mother, Sally Reed, based on this discriminatory statute, despite both being equally entitled under the law. The relevant Idaho code sections specified the order of entitlement but mandated male preference among equally entitled applicants. Sally Reed appealed, and the District Court of Idaho ruled that the statute was unconstitutional, ordering the case back to probate court to assess which party was more qualified to manage the estate. The original probate court had not evaluated the relative capabilities of the applicants, strictly adhering to the statutory preference for males. Cecil Reed appealed to the Idaho Supreme Court after a district court decision. The Supreme Court reversed the lower court, reinstating the original order that appointed the father as the estate administrator. It clarified that under Section 15-312, both parents are equally entitled to letters of administration, but Section 15-314 mandates a preference for males, leaving no discretion for the probate court. The Court rejected Sally Reed's argument that Section 15-314 violated the Equal Protection Clause by favoring males without considering individual qualifications. Sally then sought review from the U.S. Supreme Court, which acknowledged probable jurisdiction. The U.S. Supreme Court determined that the male preference in Section 15-314 does not align with the Fourteenth Amendment's equal protection requirements. Although women can obtain letters of administration under certain circumstances, Section 15-314 treats male and female applicants differently when both seek letters from the same class, establishing a classification that warranted Equal Protection scrutiny. The Court noted that while states can treat different classes differently, any classification must be reasonable and relevant to the legislative objective. The central issue was whether gender differences among applicants for letters of administration relate rationally to the objectives of the applicable statutes. The Idaho Supreme Court upheld a section of the probate code aimed at reducing disputes over letters of administration when multiple parties are equally entitled. However, it ruled that the preference given to one sex over another in the selection process violates the Equal Protection Clause of the Fourteenth Amendment. The court emphasized that favoring one gender to avoid hearings on merit constitutes an arbitrary legislative choice, which is impermissible. It also noted that Section 15—314, even as a modification of Section 15—312, does not align with constitutional standards because it creates unequal treatment for similarly situated individuals based solely on sex. Consequently, the court reversed the lower court's judgment and remanded the case for further proceedings. Additionally, it acknowledged the upcoming repeal of the challenged sections with the adoption of the Uniform Probate Code, which does not include gender preference for estate administrators.