Lalli v. Lalli (1978) 439 U.S. 259 involved a constitutional challenge to a New York statute that allowed a nonmarital child to inherit from an intestate father only if a court had issued a paternity decree during the father's lifetime. (Lalli, supra, 439 U.S. at pp. 261-262.) Drafted by a state commission of experts "in the practical problems of estate administration" (id. at p. 269), the statute "was intended to soften the rigors of previous law which permitted illegitimate children to inherit only from their mothers" (id. at p. 266). "Although the overarching purpose of the proposed statute was 'to alleviate the plight of the illegitimate child,' the commission considered it necessary to impose the strictures of the challenged statutory provision in order to mitigate serious difficulties in the administration of the estates of both testate and intestate decedents." (Id. at pp. 269-270.) The commission recognized that a putative father often "'goes his way unconscious'" of the birth of a child. (Id. at p. 269.) The commission identified serious problems which would arise in both intestacy and will probate proceedings if nonmarital children were unconditionally entitled to notice and an opportunity to be heard. For example, "'how does one cite and serve an illegitimate of whose existence neither family nor personal representative may be aware? And of greatest concern, how does one achieve finality of decree in any estate when there always exists the possibility however remote of a secret illegitimate lurking in the buried past of a parent or an ancestor of a class of beneficiaries?'" (Id. at p. 270.) In Lalli, a divided Supreme Court held the statute was "substantially related to the important state interests the statute is intended to promote" and therefore found no violation of the equal protection clause. (Lalli, supra, 439 U.S. at pp. 275-276 (plur. opn. of Powell, J.).) Justice Powell's plurality opinion observed that the statute was intended "to ensure the accurate resolution of claims of paternity ... , to minimize the potential for disruption of estate administration," and to permit a man to defend his reputation against unjust paternity claims. (Id. at p. 271 (plur. opn. of Powell, J.).) The plurality held the statute bore a substantial relationship to those purposes: "The administration of an estate will be facilitated, and the possibility of delay and uncertainty minimized, where the entitlement of an illegitimate child to notice and participation is a matter of judicial record before the administration commences." (Ibid.) Lalli recognized that in some cases, unfairness would result: "We do not question that there will be some illegitimate children who would be able to establish their relationship to their deceased fathers without serious disruption of the administration of estates and that, as applied to such individuals, the statute appears to operate unfairly. But few statutory classifications are entirely free from the criticism that they sometimes produce inequitable results. Our inquiry under the Equal Protection Clause does not focus on the abstract 'fairness' of a state law, but on whether the statute's relation to the state interests it is intended to promote is so tenuous that it lacks the rationality contemplated by the Fourteenth Amendment." (Lalli, supra, 439 U.S. at pp. 272-273.)