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Mills v. Habluetzel

• 1981 • 456 U.S. 91 • Burger Court
The U.S. Supreme Court case Mills v. Habluetzel in 1981 addressed the issue of child support and paternity laws, specifically focusing on Texas' statute that limited a mother's ability to establish paternity and seek child support from the biological father if more than one year had passed since the birth of the child. The plaintiff, Mills, argued this law violated her Fourteenth Amendment rights to equal protection under federal law because it unfairly discriminated against children born out...Open Case
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Chief Burger Court
Term: 1981
Docket: 80-6298
456 U.S. 91
102 S. Ct. 1549
71 L. Ed. 2d 770
1982 U.S. LEXIS 93
Argued: Jan 12, 1982

Mills v. Habluetzel

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Opinion Summary
AI Abstract

The U.S. Supreme Court case Mills v. Habluetzel in 1981 addressed the issue of child support and paternity laws, specifically focusing on Texas' statute that limited a mother's ability to establish paternity and seek child support from the biological father if more than one year had passed since the birth of the child. The plaintiff, Mills, argued this law violated her Fourteenth Amendment rights to equal protection under federal law because it unfairly discriminated against children born out of wedlock by limiting their opportunity for financial support compared to those born within marriage who could seek such support at any time. The court ruled in favor of Mills stating that while states have an interest in preventing fraudulent claims for child support, this interest does not justify imposing a limitation period which can deprive legitimate claimants (children) from obtaining much-needed financial assistance. It held that Texas’ one-year statute was unconstitutional as it did not meet its intended purpose - avoiding litigation over stale or fraudulent claims - but instead created an arbitrary barrier denying illegitimate children equal protection under law.

Dissent Summary
AI Abstract

In the dissenting opinion for Mills v. Habluetzel, Justice William Rehnquist argued that the majority's decision was a misinterpretation of the Equal Protection Clause of the Fourteenth Amendment. He contended that Texas' statute imposing a one-year limitation on paternity suits did not discriminate against illegitimate children but rather sought to prevent fraudulent claims and ensure reliable evidence in such cases. The state had an interest in avoiding litigation based on stale or fraudulent claims which could be facilitated by a longer statute of limitations period. Furthermore, he believed that it was inappropriate for federal courts to impose their own views about what constitutes fair treatment under state law when there is no clear constitutional violation involved.

Opinion written by Justice WHRehnquist
Decided: Apr 05, 1982
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Argued: Oct 05, 2026
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