Parents Opposed to Punitive Support v. Gardner

In 1985, Washington’s governor, Booth Gardner (defendant) formed a task force pursuant to Congress’s mandate requiring states to create presumptive child-support guidelines. Following the task force’s recommendation, the state legislature passed into law a presumptive child-support schedule (schedule). Judicial courts were instructed to utilize the schedule for determining the appropriate child-support obligation based on the income of both the obligator and obligee and the number of children in the family. Courts were permitted to deviate from the obligation determined by the schedule based on factors such as wealth, income of other adults, debt, children from other relationships, and whether the obligator spent significant time with the child. In enacting the schedule, the legislature intended to ensure that obligations were based on economic data and that decisions regarding obligations would be more equitable and predictable. Parents Opposed to Punitive Support (POPS) (plaintiff) sued Gardner on the ground that the schedule was violative of both the Due Process Clause and the Equal Protection Clause in the Fourteenth Amendment to the United States Constitution. POPS alleged that the schedule violated parents’ due-process rights by interfering with a parent’s right to remarry and have additional children due to the financial burdens. POPS also alleged that the schedule affected the relationship between the noncustodial parent and the child because it created major financial frustrations for parents. POPS alleged that the schedule violated their equal-protection rights because discrimination against noncustodial parents required more than a rational-basis review and, in the alternative, the schedule could not pass a rational-basis review. Gardner moved for summary judgment, which the district court granted. POPS appealed.