Zablocki v. Redhail

434 U.S. 374 (1978)

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Nature of the Case

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Facts

Under a Wisconsin law, a pre-condition to marriage is satisfaction of child support payments. The purported purpose of the Wisconsin law is to prevent children from becoming public charges and advising individuals of their child support obligations. Redhail's (P) certificate for marriage was denied by Zablocki (D) because he had failed to pay $109 per month in child support payments. P's prospective bride was pregnant at that time. P’s claimed that he was unable to satisfy his child support obligations because he was a poor, unemployed high school student. P brought this class action under 42 U.S.C. § 1983, challenging the statute as violative of the Equal Protection and Due Process Clauses of the Fourteenth Amendment and seeking declaratory and injunctive relief. A three-judge panel analyzed the challenged statute under the Equal Protection Clause and concluded that 'strict scrutiny' was required because the classification created by the statute infringed upon a fundamental right, the right to marry. The court then proceeded to evaluate the interests advanced by the State to justify the statute, and, finding that the classification was not necessary for the achievement of those interests, the court held the statute invalid and enjoined the county clerks from enforcing it. D appealed. The U.S. Supreme Court affirmed.