406 U.S. 164, 92 S. Ct. 1400 (1972)
Henry Clyde Stokes died on June 22, 1967, from injuries received the previous day during the course of his employment in Louisiana.1 At the time of his death Stokes resided and maintained a household with Willie Mae Weber, to whom he was not married.2 Living in the household were four legitimate minor children born of the marriage between Stokes and Adlay Jones Stokes, who was at the time committed to a mental hospital.3 Also living in the home was one unacknowledged illegitimate child born of the relationship between Stokes and Willie Mae Weber, and a second illegitimate child of Stokes and Weber was born posthumously.4
On June 29, 1967, Stokes' four legitimate children, through their maternal grandmother as guardian, filed a claim for their father's death under Louisiana's workmen's compensation law.5 The defendant employer and its insurer impleaded Willie Mae Weber, who appeared and claimed compensation benefits for the two illegitimate children.6
Meanwhile the four legitimate children had brought another suit for their father's death against a third-party tortfeasor, which was settled for an amount in excess of the maximum benefits allowable under workmen's compensation.7 The illegitimate children did not share in this settlement.8 Subsequently the employer in the initial action requested the extinguishment of all parties' workmen's compensation claims by reason of the tort settlement.9
The trial judge awarded the four legitimate children the maximum allowable amount of compensation and declared their entitlement had been satisfied from the tort suit settlement, so the four legitimate children dismissed their workmen's compensation claim.10 Judgment was also awarded to Stokes' two illegitimate offspring to the extent that maximum compensation benefits were not exhausted by the four legitimate children.11 Since such benefits had been entirely exhausted by the amount of the tort settlement in which only the four dependent legitimate offspring participated, the two dependent illegitimate children received nothing.12
Both the Louisiana Court of Appeal and a divided Louisiana Supreme Court sustained the statutes over constitutional objections.13 The United States Supreme Court granted certiorari to review the case.14
Whether Louisiana workmen's compensation laws deny dependent unacknowledged illegitimate children recovery rights on an equal footing with dependent legitimate children?15
The Equal Protection Clause of the Fourteenth Amendment requires that a statutory classification bear some rational relationship to a legitimate state purpose.16 When classifications approach sensitive areas such as illegitimacy or fundamental personal rights, stricter scrutiny applies.17 The essential inquiry remains whether the classification promotes a legitimate state interest and what personal rights it might endanger.18 Louisiana law defines children to include only legitimate children, stepchildren, posthumous children, adopted children, and illegitimate children acknowledged under Civil Code Articles 203, 204, and 205.19 Unacknowledged illegitimate children are relegated to the lesser status of other dependents.20 They recover only after preferred classes exhaust maximum benefits.21 This distinction bears no rational relationship to the purposes of compensating dependents for loss of support.22
Yes. The rule requires every classification to rest on a rational relationship to a legitimate purpose.23 Here the Louisiana statutes draw an impermissible line based on acknowledgment and legitimacy.24 All six children lived in Stokes' household and were equally dependent on him for maintenance and support.25 Yet the four legitimate children exhausted the maximum benefits through their separate tort settlement while the two unacknowledged illegitimate children received nothing.26 The statutes define children to include only those acknowledged under specified Civil Code articles.27 They treat unacknowledged illegitimates as secondary claimants.28 The record shows the dependency and natural affinity of the unacknowledged children were as great as those of the legitimate children.29
The state interest in protecting legitimate family relationships is not served by the statute.30 The compensation scheme already limits recovery to actual dependents.31 The interest in minimizing proof problems is not significantly disturbed by the decision.32 The dependency prerequisite already confines claimants to those in a direct blood and dependency relationship.33 The classification therefore lacks any rational basis under the Equal Protection Clause.34
Louisiana's workmen's compensation laws deny dependent unacknowledged illegitimate children recovery rights on an equal footing with dependent legitimate children in violation of the Equal Protection Clause of the Fourteenth Amendment.35
Related opinions on this issue
Justice Blackmun concurred only in the result.36 He placed primary emphasis on Louisiana Civil Code Article 204, which barred Henry Stokes from acknowledging his illegitimate children because he remained married to another woman and thus could not contract marriage with their mother.37 This statutory barrier alone denied equal protection to the children.38
Blackmun would not extend the holding to situations where a father possesses the legal power to acknowledge his illegitimate children yet refrains from doing so.39 He viewed the majority opinion as reaching too far by striking down the entire scheme even absent the acknowledgment barrier.40
Justice Rehnquist dissented.41 He regarded Levy v. Louisiana as wrongly decided and would have followed the more recent decision in Labine v. Vincent to uphold the classification.42 Rehnquist argued that the traditional rational-basis standard governs economic and social legislation such as workmen's compensation.43 The distinction between acknowledged and unacknowledged children rationally serves the state's interest in encouraging responsible family relationships and reducing problems of proof.44
He viewed the majority's search for legitimate interests and fundamental rights as an unwarranted judicial superstructure lacking support in the text or history of the Equal Protection Clause.45