Reed v. Reed, 404 U.S. 71 (1971)
Author: Burger (unanimous) Outcome: Appellant wins ($d = 1$: gender-based preference violates EP) Concurrences: None Dissents: None
1. Holding ($H_t$)
"A mandatory provision of the Idaho probate code that gives preference to men over women when persons of the same entitlement class apply for appointment as administrator of a decedent's estate is based solely on a discrimination prohibited by and therefore violative of the Equal Protection Clause of the Fourteenth Amendment." (p. 71)
As constraint on admissible $(w, c)$: Rules out any decision rule under which a state can mandate gender-based preferences in the administration of estates. Formally: if $z$ has (gender classification = explicit, entitlement class = equal), then admissible $(w, c)$ must map to $d = 1$ (invalidate). The weight on gender equality must be large enough to override any administrative convenience justifications.
What the holding does NOT constrain:
- Whether gender classifications in contexts other than estate administration are subject to the same rule
- The level of scrutiny applied to gender classifications (rational basis vs. heightened scrutiny is not specified)
- Whether other forms of administrative efficiency could justify different classifications
- The broader implications for gender equality in other legal contexts
2. Fact vector $z_t$
2a. Raw salient facts
- Gender-based statutory preference: Idaho Code § 15-314 mandates preference for males over females in estate administration when applicants are equally entitled (p. 71). Favors: government.
- Equal entitlement class: Both the mother and father of the deceased are in the same entitlement class under Idaho Code § 15-312 (p. 71). Favors: plaintiff.
- No assessment of individual qualifications: The probate court did not assess the relative capabilities of the applicants, relying solely on statutory preference (p. 71). Favors: plaintiff.
- Administrative convenience: The Idaho Supreme Court justified the gender preference as a means to reduce probate court workload (p. 71). Favors: government.
2b. Dimension mapping
| Dimension | Value | Raw fact(s) mapped | Textual basis |
|---|---|---|---|
| D1 Facial classification | High | Gender-based statutory preference | Idaho Code § 15-314 mandates preference for males (p. 71) |
| D2 Protected trait | Sex | Gender-based statutory preference | Throughout |
| D3 Intent evidence | N/A (facial) | — | Classification is explicit; no need to infer intent |
| D4 Interest strength | Weak | Administrative convenience | "objective of reducing the workload on probate courts" (p. 71) |
| D5 Means-ends fit | Poor | No assessment of individual qualifications | "the probate judge considered himself bound by statute" (p. 71) |
| D6 Stigma / caste | Low | Not addressed | — |
| D7 Institutional setting | Probate court | Administrative convenience | "eliminate one area of controversy" (p. 71) |
| D8 Precedent density | Low | — | No prior Supreme Court cases directly on point |
Unmapped facts:
- The broader societal context of gender discrimination is not directly addressed in the opinion, though it underlies the Court's reasoning. This might suggest a dimension capturing societal equality norms.
Notable: The Court does not specify a level of scrutiny, which leaves open the question of whether gender classifications require heightened scrutiny or merely rational basis review.
3. Treatment of prior holdings ($\mathcal{F}_t$ update)
The Court does not substantively engage with prior holdings in this opinion, as it addresses a novel issue of gender discrimination in estate administration. The decision establishes a new constraint on $\mathcal{F}_t$ by invalidating gender-based statutory preferences without relying on precedent.
4. Overruling (constraint removal at cost $C$)
No overruling in this case. The Court does not explicitly overrule any prior decisions, as the issue of gender-based preferences in estate administration had not been previously addressed at the Supreme Court level.
5. Breadth
Narrow reading (what the Court explicitly holds):
- Gender-based preferences in estate administration violate the Equal Protection Clause when applicants are equally entitled.
- Limited to the specific context of probate court administration under Idaho law.
Broad reading (what the reasoning supports):
- The reasoning could extend to other contexts where gender-based preferences are justified solely by administrative convenience, suggesting a broader prohibition on such preferences.
Breadth ambiguity: The opinion does not specify the level of scrutiny for gender classifications, leaving ambiguity about how broadly the reasoning applies to other gender discrimination cases. The decision could be read narrowly as addressing only probate administration or broadly as a step towards heightened scrutiny for gender-based laws.
6. Concurrences / dissents (alternative admissible theories)
None. The opinion is unanimous and joined by all Justices. The lack of separate opinions suggests a consensus on the unconstitutionality of gender-based preferences in this context, though it leaves open questions about the broader implications for gender discrimination law.
7. Reasoning revealing implicit weights on dimensions
Administrative convenience is insufficient (D4 weight is low):
"The crucial question, however, is whether § 15-314 advances that objective in a manner consistent with the command of the Equal Protection Clause. We hold that it does not." (p. 71)
The Court signals that administrative convenience cannot justify gender-based classifications, indicating a low weight on D4 (interest strength).
Facial gender classification is problematic (D1 weight is high):
"To give a mandatory preference to members of either sex over members of 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." (p. 71)
The Court emphasizes the arbitrariness of facial gender classifications, suggesting a high weight on D1 (facial classification).
Equality within entitlement classes (D5 weight is high):
"By providing dissimilar treatment for men and women who are thus similarly situated, the challenged section violates the Equal Protection Clause." (p. 71)
The Court underscores the importance of treating similarly situated individuals equally, indicating a high weight on D5 (means-ends fit).