Stanley v. Stanley

FROEB, Judge

(dissenting):

I differ from the majority in their view of the nature of rights and duties altered by the Legislature in reducing the age of majority from twenty-one to eighteen.

When the Legislature enacted this change it altered the legal status of all minors who had attained or would attain in the future the age of eighteen from and *41after August 13, 1972, the effective date of the act. The legislation was neither retrospective nor prospective in its operation. It affected all minors upon its effective date.

The Arizona Supreme Court has held, “ . . . the rule is settled beyond a doubt that majority or minority is a status rather than a fixed or vested right, and that the legislature has full power to fix and change the age of majority.” Valley National Bank of Phoenix v. Glover, 62 Ariz. 538, 558, 159 P.2d 292, 301 (1945). There are no vested rights in future child support payments. Jungjohann v. Jungjohann, 213 Kan. 329, 516 P.2d 904 (1973); Shoaf v. Shoaf, 282 N.C. 287, 192 S.E.2d 299 (1972). Similarly, there are no vested property rights in personal privileges that attach during a minority status. Rice v. Rice, 213 Kan. 800, 518 P.2d 477 (1974).

The reasoning of the majority opinion applies a vested rights theory to minority status. But if these rights are vested, at what point do they vest? Under the majority view it would seem that any person born prior to August 13, 1972, would be entitled to support until age twenty-one and it would not be limited to those persons for whom there had been a court order for support prior to that date.

I note that the reduction in the age of majority by the Legislature was comprehensive legislation which amended no fewer than 90 sections of Arizona Revised Statutes. Chapter 146, Laws 1972. Yet, I can find only two instances where the Legislature, using express language, preserved the minority status for some members of the class until age twenty-one and these are unrelated to the duty of support. See Chapter 146, Sections 88 and 89, Laws of 1972. With these two exceptions no intent can be found in this legislation that some minor children would become adults at eighteen while others would wait until reaching twenty-one.

The rights and duties at issue in this case are those which arise by virtue of the child support laws in Arizona and not by reason of any agreement of the parties. Thus Ruhsam v. Ruhsam, 110 Ariz. 326, 518 P.2d 576 (1974), modified 110 Ariz. 426, 520 P.2d 298 (1974) has no application here, since in that case there had been contractual arrangements between the parents concerning support for the minor child. The existence of the agreement was pivotal in that decision.

The court has continuing jurisdiction to modify orders of support which it has entered for the benefit of a minor child. Thus there is no vested right to continued support in a certain monetary amount where circumstances are shown to have changed. Likewise the change brought about by the Legislature in reducing the age of majority from twenty-one to eighteen is in the same category, only in the latter instance it is brought about by changes in the law generally through legislative enactment rather than a change wrought by the parties in an individual case. Can it be said that there was neither intent nor authority in the legislation here at issue to accomplish that which the courts undertake each day?

The Baker, Strum, Vicino and Waldron cases cited by the majority support their conclusion but in my view they diverge from sound legal principle. The holding of the North Carolina Supreme Court in Shoaf v. Shoaf, supra, which considered the precise issue involved here, seems to me more persuasive. The court there held:

“A child support payment falls in the same category as an alimony payment and becomes subject to review by the court upon change of conditions. The Legislature unequivocally changed the conditions by fixing a different date upon which liability to support a child terminated.” 192 S.E.2d at 303.

For the reasons stated, I would affirm the order of the trial court terminating the appellee’s obligation of support when the minor child reached eighteen.