Palmore v. Sidoti

In Palmore v. Sidoti (1984) 466 U.S. 429, the United States Supreme Court concluded that a state trial court had violated the equal protection clause by awarding a father custody of a child after the mother married an African-American. The trial court based its award on the rationale that the child would likely suffer social stigma from the interracial marriage of his mother. (466 U.S. at p. 431.) In concluding that this order violated the equal protection clause, the Palmore court endorsed the best interest standard for adjudicating custody disputes between parents. (466 U.S. at p. 432 "The trial court correctly stated that the child's welfare was the controlling factor.".) The Palmore court further explained: "The State, of course, has a duty of the highest order to protect the interests of minor children, particularly those of tender years. In common with most states, Florida law mandates that custody determinations be made in the best interests of the children involved. The goal of granting custody based on the best interests of the child is indisputably a substantial governmental interest for purposes of the Equal Protection Clause." (Id. at p. 433.) The Palmore court was clear that the court was reversing the trial court's order because of "the Constitution's commitment to eradicating discrimination based on race." (Palmore, supra, 466 U.S. at p. 432.)