Boykin v. Phillips

1 Va. Cir. 228, 1981 Va. Cir. LEXIS 6
CourtHenrico County Circuit Court
DecidedJuly 13, 1981
DocketCase No. 81-M-94
StatusPublished

This text of 1 Va. Cir. 228 (Boykin v. Phillips) is published on Counsel Stack Legal Research, covering Henrico County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Boykin v. Phillips, 1 Va. Cir. 228, 1981 Va. Cir. LEXIS 6 (Va. Super. Ct. 1981).

Opinion

By JUDGE BALLARD BAKER

This is a child support complaint filed by Patricia Boykin, a New Jersey resident, against Leon Phillips, alleging that Phillips is the father of Rahiem Leon Boykin, born December 31, 1979. She seeks to have paternity established and a support order entered, and is proceeding under the Revised Uniform Reciprocal Enforcement of Support Act. (URESA, V.C. § 20-88.12 - § 20-88.31).

The Juvenile and Domestic Relations Court found paternity established and set support at $130.00 per month. Appeal was taken by Phillips. Evidence was heard on June 1, 1981 and counsel were given an opportunity to file authorities.

At the hearing, Boykin said Phillips was the father; Phillips said he was not. Dr. Ali Hossani, Director of the Paternity Testing Lab at the Medical College of Virginia, testified that based upon the [229]*229blood grouping test he had performed on the parties and the child, the chances were 16 to 1 that Phillips was the father. He converted this to a 94.23% probability. None of the eight tests performed excluded Phillips.

The blood grouping test was performed pursuant to § 20-61.2, under order of the Juvenile Court. The major issue is whether the test result is properly ordered and the results received.

Under URESA, § 20-88.26:1 allows the responding state to "... adjudicate the paternity issue within the same limits as provided in § 20-61.1".

Section 20-61.1 limits the nature of the evidence which may be considered in determining paternity in proceedings under Chapter 5 of Title 20. It does not include the blood test procedure. URESA is not in Chapter 5.

As noted, § 20-61.2 permits a blood grouping test and does so "In the trial of any divorce or support proceedings in any court in which the question of paternity arises. . ." This section goes back at least to 1966 (Acts of General Assembly, 1966, Chapter 517), and for many years was in the Code as § 8-329.1. In the 1977 revision of Title 8, the section became 20-61.2. (Acts 1977, Chapter 624, p. 1227). The Report of the Code Commission, Revision of Title 8, indicates that it transferred 8-329.1 to Title 20, but does not give any reason.

If the Court is limited to the evidence permitted in a proceeding governed by 20-61.1, Boykin cannot prevail. If the blood grouping test of 20-61.2 can be required and the results considered, then Boykin can prevail.

While the case is brought in the name of the mother, it is the right of the child to support that is involved, and this Court considers the case in that light.

[230]*230At the outset, it is observed that URESA does not by its language limit the civil child support right to legitimate children. Its reference to § 20-61.1 may give rise to the argument that it is intended to be limited to the same type case, but to limit it to such raises a constitutional issue commented on hereafter.

Section 20-88.26:1 in URESA refers to determination of paternity ". . . as provided in section 20-61.1”. This particular section (20-88.26:1) came into the law in 1970, (Acts 1970, Chap. 669, p. 1482), at which time the original URESA law was amended. Section 8-329.1, which is now 20-61.2, was in the Code in 1970, and the General Assembly could have had 20-88.26:1 include it as well as 20-61.1. The failure of the legislature to do this seems to preclude this Court from giving a liberal interpretation of 20-88.26:1 to include 20-61.2 (or what was 8-329.1 in 1970). This, I think is true despite § 20-88.18.

That, however, does not resolve the issue. Under a series of Supreme Court cases, it is this Court's view that the right of an illegitimate child to support under the law of Virginia cannot be less than the right of a legitimate child. Levy v. Louisiana, 391 U.S. 68 (1968); Gomez v. Perez, 93 S.Ct. 872 (1973). Nor can Virginia deny to a non-resident child the same rights it affords to a resident child with respect to support from its parents. Art. IV, section 2, Constitution of the United States; 16A Am. Jur. 2d, Constitutional Law, sect. 730.

In Gomez, the Supreme Court held
. . . that once a State posits a judicially enforceable right on behalf of children to needed support from their natural fathers there is no constitutionally sufficient justification for denying such an essential right to a child simply because its natural father has not married its mother. (93 S. Ct. at 875).

[231]*231Virginia does have a judicially enforceable right of a child with respect to support from its natural father. This right is not limited to the criminal sanctions of § 20-61. Juvenile courts have jurisdiction in this field in civil proceedings, (§ 16.1-241), as do Circuit courts in divorce matters, (§ 20-107). Virginia also affords this right to nonresident children under URESA, sections 20-88.12 to 20-88.31.

Involved here is not whether Virginia gives a civil support right to illegitimate children as required by Gomez. Virginia must. The issue here is whether an evidentiary procedure permitted in Virginia by § 20-61.2 applies to a civil support case involving an illegitimate child, whether she be resident or non-resident. Is § 20-61.2 limited to cases involving legitimate children, and, if so, is such limitation constitutional?

In my judgment, the answer to each question is No.

Nothing in 20-61.2 says that only children born in wedlock, or born of a married woman, may have the blood grouping test. The test is permitted in ”. . . the trial of any divorce or support proceeding. . ." While a divorce proceeding requires an existing marriage, a support proceeding can involve unwed parties, as in this case.

The right to have the blood grouping test, like the civil support remedy given by URESA, is not limited by its language to legitimate children. To say that it must be construed to apply to legitimate children only is to say that, in some cases, the outcome of the test determines the right to have it performed, which would be somewhat odd.

It may be argued that 20-61.2 is to apply only to children born in wedlock or born of a married woman, but not to support cases such as this where there is no marriage. Construed in this way means an evidentiary right would be given to a child whose [232]*232mother was married but not given to a child whose mother was not married. While this is not what Gomez specifically disallows, it is not consistent to say that a state, having given a right to support to one class of children which must also be given to another class or be unconstitutional, can give an evidentiary aid such as 20-61.2 to the one class and not allow the same aid to the other.

The same reasoning requires rejection of the argument that the reference in 20-88.26:1 to 20-61.1 limits URESA civil child support actions to the same class of children or same type of case contemplated by 20-61.1. Virginia, having given a civil support right to resident children, legitimate or illegitimate, cannot discriminate between non-resident legitimate and illegitimate children with respect to a civil support right. If that be true, as it must under Gomez and the Constitution, it is inconsistent to say resident children have an evidentiary right that nonresident children of unwed mothers cannot enjoy.

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Related

Levy v. Louisiana Ex Rel. Charity Hospital
391 U.S. 68 (Supreme Court, 1968)
Gomez v. Perez
409 U.S. 535 (Supreme Court, 1973)
Brown v. Commonwealth Ex Rel. Custis
235 S.E.2d 325 (Supreme Court of Virginia, 1977)

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Bluebook (online)
1 Va. Cir. 228, 1981 Va. Cir. LEXIS 6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/boykin-v-phillips-vacchenrico-1981.