Constructive Emancipation: The Breakdown of a Relationship Between Parent and Child and the Termination of Child Support

Within the last month, the Appellate Division, Second Department, has decided several interesting family law cases. One, in particular, directly answers a question I am frequently asked, which, in some form, goes like this: My son refuses to visit me; do I have to pay child support for him?

The answer, as supplied by the Court in the case of Gold v. Fisher, is- it depends.

. . . .a child of employable age who actively abandons the non-custodial parent by refusing all contact and visitation" may forfeit any entitlement to support In contrast, where it is the parent who causes a breakdown in communication with his child, or has made no serious effort to contact the child and exercise his visitation rights, the child will not be deemed to have abandoned the parent.

The parent seeking to have the child “constructively emancipated” has the burden of proof. From my experience, given that this is a drastic remedy, which may punish the custodial parent (who may or may not be at fault) as much as the child, courts strive to discover the true origins of breakdown of non custodial parent-child relationship.

If the evidence shows that the non-custodial parent is in any way at fault for the estrangement, the application will be denied and the obligation to pay support will continue. If the non-custodial parent is blameless, support will be terminated.
 

578 Responses

  1. Richard
    HI, my name is Richard Claudio and i have a unique situation with my daughter were i need an opinion on this matter please.MY daughter is 19 years old and has a 9 month old baby her self. My question is , should or do i have to keep paying her child support all though she decided to make an adult decision herself to have a child of here own? if this situation emancipatable or does the new york law state that i will still have to support here even if she has a child of her own? is this possible, cause it just dont sound fair to me. thank you so much for your time.
  2. shonna
    I have a 15 yr old stepdaughter that wishes to emencipate or somehow get her biological mother out of her life. We have taken care of her since 2002, with her mother in and out of her life. For 3 months now she has not spoken to her and refuses to have anything to do with her mother. Me and her father took her away from her do to verbal and physical abuse. what rights do we have or how do we need to go about this. Does my stepdaughter need an attorney, can we somehow remove all rights, how does this work? HELP
  3. Wendy
    I have a son who just turned 18. Over the past 4 years he has been in trouble at school, swearing at teachers, failing school, using drugs, he has been physically and verbally abusive to me, I am his mother, and to his step-father He has failed drug tests for THC and Morphine. He is currently repeating the entire 11 grade this year and I do not think he passed anything again. Which means he is now 18 and possibly repeating 11th grade for the 3rd time. Last month I realized that I was missing a necklace well at first I thought only a necklace but he had actually taken a bunch of my and my husbands gold jewelry. I kicked him out of the house, he is staying with his girlfriend's parents and I have been sending them $100.00 a week to feed him. Apparently someone told him that I have to pay him child support so he can get an apartment can this be true. I have school records and police records to prove that I did all that I could do for this kid. I had Childrens Coordinated Services involved, a Therapist, a probation officer, we even had to see a judge every six weeks for a while. My son was in jail for ten days about 1 1/2 years ago for slapping me on the back and punching/putting a hole in a door in our house, all because I would not let him go to a party because he had cut school. I was given an order of protection and he was court ordered to live at a group home for two months.
  4. kelly
    Wendy. I haver a very similar situation.My son is 16. He wentto live with his father. He has gotten into trouble..stealing..etc. Cant you have emancipated since he abandoned the home?what county do you live in?
  5. John
    The law in New Jersey that requires only divorcing and non-custodial parents to pay adult child support and pay higher education costs for their adult children is unconstitutional. NEW JERSEY LAW FOR ADULT CHILD SUPPORT & HIGHER EDUCATION In New Jersey, the Legislature and our courts have long recognized a child's (a young adult’s) need for higher education and that this need is a proper consideration in determining a parent's adult child support & higher education obligation. Writing for the Court in Newburgh, Justice Pollock set forth a non-exhaustive list of twelve factors a court should consider in evaluating a claim for contribution toward the cost of higher education. See Newburgh v. Arrigo, 88 N.J. 529 (1982).     The enumerated factors are as follows: (1) whether the parent, if still living with the child, would have contributed toward the costs of the requested higher education; (2) the effect of the background, values and goals of the parent on the reasonableness of the expectation of the child for higher education; (3) the amount of the contribution sought by the child for the cost of higher education; (4) the ability of the parent to pay that cost; (5) the relationship of the requested contribution to the kind of school or course of study sought by the child; (6) the financial resources of both parents; (7) the commitment to and aptitude of the child for the requested education; (8) the financial resources of the child, including assets owned individually or held in custodianship or trust; (9) the ability of the child to earn income during the school year or on vacation; (10) the availability of financial aid in the form of college grants and loans; (11) the child's relationship to the paying parent, including mutual affection and shared goals as well as responsiveness to parental advice and guidance; and (12) the relationship of the education requested to any prior training and to the overall long-range goals of the child (adult). In the aftermath of the Newburgh Decision, the Legislature essentially approved  those criteria’s when amending the support statute, N.J.S.A. 2A:34-23(a)(5). Compare N.J.S.A. 2A:34-23(a)(5) (listing factors to consider in determining support) with Newburgh, supra, 88 N.J. at 545, 443 A.2d 1031 (listing factors to consider in determining payment of education expenses). Kiken v. Kiken,  149 N.J. 441, 449, 694 A.2d 557 (1997). Thus, a trial court should balance the statutory criteria of N.J.S.A. 2A:34-23(a)(5) and the Newburgh factors, as well as any other relevant circumstances, to reach a fair and just decision whether and, if so, in what amount, a parent or parents must contribute to a child's educational expenses. The New Jersey Legislator and State Supreme Court overlooked the constitutional mandate that forbids family liberty may not be interfered with, under the guise of protecting the public interest and that parents have a fundamental right to control the education of their children. It is true that the law in question is designed to promote the highest good and public interest, but is does not make this law constitutional. THE NEW JERSEY & FEDERAL CONSTITUION SHOULD PROTECT AGAINST AN INJUSTICE THAT WOULD LEAD TO UNEQUAL TREATMENT Article I, Paragraph 1 of the New Jersey Constitution sets forth the first principles of our governmental charter – that every person possesses the “unalienable rights” to enjoy life, liberty, and property, and to pursue happiness. The Equal Protection clause of Federal Constitution provide that no person shall be denied the equal protection of the laws. U.S. Const. amend. XIV, § 1. Although our State Constitution nowhere expressly states that every person shall be entitled to the equal protection of the laws, the New Jersey Supreme Court has construed the expansive language of Article I, Paragraph 1 to embrace that fundamental guarantee. Sojourner A. v. N.J. Dep’t of Human Servs., 177 N.J. 318, 332 (2003); Greenberg v. Kimmelman 99 N.J. 552, 567-68 (1985). The first paragraph to our State Constitution “protect[s] against injustice and against the unequal treatment of those who should be treated alike.” Greenberg, supra, 99 N.J. at 568. When a statute is challenged on the ground that it does not apply evenhandedly to similarly situated people, our equal protection jurisprudence requires that the legislation, in distinguishing between two classes of people, bear a substantial relationship to a legitimate governmental purpose. Caviglia v. Royal Tours of Am., 178 N.J. 460, 472-73 (2004); Barone v. Dep’t of Human Servs., 107 N.J. 355, 368 (1987). The test that New Jersey Courts have applied to equal protection claims involves the weighing of three factors: the nature of the right at stake, the extent to which the challenged statutory scheme restricts that right, and the public need for the statutory restriction. Greenberg, supra, 99 N.J. at 567; Robinson v. Cahill, 62 N.J. 473, 491-92, cert. denied, 414 U.S. 976, 94 S. Ct. 292, 38 L.Ed. 2d 219 (1973). The test is a flexible one, measuring the importance of the right against the need for the governmental restriction. See Sojourner A., supra, 177 N.J. at 333. Under that approach, each claim is examined “on a continuum that reflects the nature of the burdened right and the importance of the governmental restriction.” Ibid. Accordingly, “the more personal the right, the greater the public need must be to justify governmental interference with the exercise of that right.” George Harms Constr. Co. v. N.J. Tpk. Auth., 137 N.J. 8, 29 (1994); see also Taxpayers Ass’n of Weymouth Twp. v. Weymouth Twp., 80 N.J. 6, 43 (1976), cert. denied, 430 U.S. 977,97 S. Ct. 1672, 52 L. Ed. 2d 373 (1977). Unless the public need justifies statutorily limiting the exercise of a claimed right, the State’s action is deemed arbitrary. See Robinson, supra, 62 N.J. at 491-92. The New Jersey equal protection analysis also differs from the more rigid, three-tiered federal equal protection methodology. When a statute is challenged under the Fourteenth Amendment’s Equal Protection Clause, one of three tiers of review applies -- strict scrutiny, intermediate scrutiny, or rational basis --depending on whether a fundamental right, protected class, or some other protected interest is in question. Clark v. Jeter, 486 U.S. 456, 461, 108 S. Ct. 1910, 1914, 100 L. Ed. 2d 465, 471 (1988). All classifications must at a minimum survive rational basis review, the lowest tier. POINT ONE Why N.J.S.A. 2A:34-23(a)(5) & New Jersey Common Law requiring only divorcing & non-custodial parents to pay adult child support & higher education costs for their adult children is unconstitutional. In cases where there is an intact family, with parents married and residing together, the statute has no application. In such cases, the parents have no legal obligation to provide support for adult children, no obligation to contribute to college education and adult children have no remedy for compelling such support. In essence, N.J.S.A. 2A:34-23(a)(5) and case law permits a burden to be imposed upon one class of citizens---divorced or separated parents---that cannot in like circumstances be imposed upon married parents residing together. Parents in this latter class are thus immune from such legal liability. Likewise, N.J.S.A. 2A:34-23(a)(5) and case law creates a privilege for one class of citizens---adult children of divorced or separated parents---that is not granted to children whose parents are married and residing together. In consequence, by establishing distinctions based upon the marital status of the parent, N.J.S.A. 2A:34-23(a)(5) and case law violates the equal protection clauses of both New Jersey and United States Constitutions. It has been said that rights cannot exist merely in theory or on paper; they must exist in reality or they are meaningless. See Cooper v. Nutley Sun Printing Co., 36 N.J. 189, 197 (1961) (New Jersey Constitution does not embody rights in a vacuum, existing only on paper. And where rights are not equal in application or practice, then the promise and guarantee of equal rights remains unfulfilled. It is a commendable practice of recognizing when “one of our decisions has consequences that were not fully anticipated.” Pinto v. Spectrum Chems. & Lab. Prods., 200 N.J. 580, 598 (2010). Logically, that axiom is equally applicable when one of its decisions has not had the remedial consequences that the Court anticipated would result. Such is the case here. A state's interest in forcing only divorced and noncustodial parents to pay adult child support and secondary education, however highly ranked, is not totally free from a balancing process when it impinges on other fundamental rights and interests. This type of law that exists in New Jersey must be struck down --- even if it is a good law. Moreover, there is no dispute that it does not apply evenhandedly to similarly situated people. Bailey v. Drexel Furniture Co. (Child Labor Tax Case), 259 U.S. 20, 37, 42 S. Ct. 449, 66 L. Ed. 817 (1922) (reviewing court must strike down unconstitutional law even though that law is “designed to promote the highest good.” The good sought in this unconstitutional law is an insidious feature, because it leads citizens, courts and legislators of good purpose to promote it, without thought of the serious breach it will make in the ark of our covenant, or the harm which will come from breaking down recognized standards. The law on its face egregiously places different burdens and benefits placed on persons similarly situated also violate the guarantees of equal protection. Jones v. Helms, 452 U.S. 412, 101 S. Ct. 2434 (4,5) (1981), South Central Bell Telephone Co. v. Alabama, 526 U.S. 160, 119 S. Ct. 1180 (1999), Romer v. Evans, 517 U.S. 620, 116 S. Ct. 1620 (1996). This law establishes distinctions that are wholly unrelated to the legitimate state interest that the law seeks to advance. The equal protection provision in the New Jersey Constitution "prohibits the State of New Jersey from adopting statutory classifications that treat similarly situated people differently." (Sanchez v. Dep't of Human Servs., 314 N.J. Super. 11, 30 (App. Div. 1998)). As I see it, the state’s interest in having a public policy and social goal for family courts to encourage higher education does not apply evenhandedly to all New Jersey Parents. It only applies to those parents who are getting divorced or never married. The law is discretionary and is routinely implemented upon a showing of need for parental assistance on the part of the individual young adult attending college. The law is clear, when no harm threatens an adult child's welfare, the State lacks a sufficiently compelling justification for the infringement on the fundamental right of parents to raise their children as they see fit. It is fundamentally unfair the way the law is applied and the State no interest in ordering parents to pay money to or for adult children regardless of the marital status of parents. The objective of the law is to provide a legal remedy for compelling parents to support their adult children who attend college and who are in need of such support (thereby advancing the state’s interest in having a well-educated populace), class distinctions restricting or limiting the law application must have a rational relationship to the law’s objective. The plight of an adult child of divorced parents, attending college and in need of parental support, is in no way different from the plight of an adult child of married parents, also attending college and in need of parental support. Young adults who need parental support for college and whose parents are divorced are not "more needy" simply because their parents are divorced, in contrast to adult children in like circumstances whose parents happen to be married. Likewise, young adults in the same situation whose parents are married are not "less needy" simply because their parents are married. Need is need; it should not be contingent on the marital status of the needy students parents. The essence of Article I, Paragraph 1 of the New Jersey Constitution, as well as the Fourteenth Amendment, is simple: like citizens in like circumstances are to be treated equally in the eyes of the law. The present law violates this fundamental constitutional principle. The law is unconstitutional and the court should so recognize. The best interest of the child rule is consistently invoked by American courts when dealing with children in custody disputes because courts have an overriding interest in protecting a minor child’s welfare. Generally, this rule is applied with the best of intentions concerning minor children. However, the best interest of the child rule should never be considered when dealing with adult child support and post-secondary education payments concerning adult children. By ordering divorcing and noncustodial parents to support their adult children, the New Jersey Courts continue to violate the constitutional rights of those parents. Treating all New Jersey parents similarly situated should be the goal of our legal system, but it isn’t in New Jersey. As noted below, the New Hampshire legislature recognized the inequality of these judicial orders and recently amended the law. SUPPORTING AUTHORITY A recent South Carolina Supreme Court struck down a similar provision mandating post-majority support as a violation of the Constitution’s Equal Protection Clause after 30 years of being the law of the land. It reasoned that since married parents do not have to support their adult children, it was discriminatory to force divorced parents to do so. See Webb v. Sowell, 387 S.C. 328, 692 S.E.2d 543 (2010), see also Curtis v. Kline, 666 A.2d 265 (Pa. 1995). Grapin v. Grapin, 450 So.2d 853 (Fla. 1984). The Florida Supreme Court found based on equal protection grounds, that is was fundamentally unfair and a denial of equal protection under the law to impose the duty of supporting a post-majority child on divorced parents but not on the parents who are married to each other. In Ohio, the law regarding payment of post-secondary education expenses is well settled and set forth in Bardes v. Todd 746 N.E.2d 229, 235 (Ohio App. 1st Dist. 2000).In Bardes, the court restated the rule regarding payment of post-secondary educational expenses as follows: without a specific agreement of the parties and the subsequent adoption of the agreement by a trial court, a judge generally has no authority to issue orders setting aside money for future college expenses of a minor child. However, this rule only applies if the money would be used after the child reaches the age of majority. In addition, the Bardes court stated that no case law supported a holding that attending a college of one’s choice is a fundamental right guaranteed by the federal Constitution, even for the most gifted of children. SUPPORTING LEGLISLATIVE ACTION In January of 2003, the New Hampshire legislature introduced a bill proposing to change the existing law regarding post-secondary education orders. The previous statute, which applied before the amendment was introduced, granted superior courts the authority to order divorced parents to contribute to their child’s post-secondary educational expenses. This new bill was drafted to amend RSA § 458:17 by inserting the following provision: “No child support order shall require a parent to contribute to an adult child’s college expenses or other educational expenses beyond the completion of high school.” The purpose of this provision, according to the bill’s sponsor, was to remove a trial judge’s discretion when ordering divorced parents to contribute to their adult child’s college expenses. Both the Senate and the House of Representatives voted in favor of the bill, and on January 1, 2004, the new child support provision took effect. The new law is codified as RSA § 458:17(XI-a). In February, 2010 the Virginia legislators killed a bill to extend child support to adult college students. The bills would have required a non-custodial parent to make payments to the other parent while their adult child is attending college. A limited number of states have such laws, but legislators in Virginia voted the bill down after receiving an avalanche of angry e-mails and phone calls from their constituents opposing the bill. The bill was killed by the House of Delegates Courts of Justice Committee in an voice vote on January 22 2010 to strike the bill from the docket. It was killed this legislative session by the Senate Courts of Justice Committee, which voted 13-to-1 to shelve the bill indefinitely. On February 1, 2010 only Senator Roscoe Reynolds (D-Martinsville) voted to keep the bill alive. POINT TWO THE PUBLIC POLICY AND SOCIAL GOAL OF THE NEW JERSEY FAMILY COURTS TO ENCOURAGE HIGHER EDUCATION OFFENDS THE FUNDAMMENTAL RIGHTS OF A SELECT CLASS OF PARENTS It is now well established that family integrity is a fundamental right that the State my not abridge through it’s public policy. The Due Process Clause of the Fourteenth Amendment protects fundamental liberties such as family integrity. Here, the State’s “Public Policy On Forcing Only A Select Class of Parents To Pay Adult Child Support And College Contribution” violate due process because they (i) result in the deprivation of family rights without requiring the government to satisfy any minimum threshold to justify such an obligation to only a select class of parents, and (ii) do not provide procedural protections to ensure that parents’ rights are not trammeled unlawfully and that state officials operate within the law. The Public Policy in question vest state officials with unfettered discretion to infringe upon a selected class of parents’ fundamental family rights. A. Family Integrity Is A Fundamental Right. The Due Process Clause of the Fourteenth Amendment provides that no State shall “deprive any person of life, liberty, or property, without due process of law.” As this Court has explained, the Due Process Clause protects the fundamental liberties of private citizens from undue interference by the government. “[T]he Due Process Clause, like its forebear in the Magna Carta, was “‘intended to secure the individual from the arbitrary exercise of the powers of government.’””Daniels v. Williams, 474 U.S. 327, 331 (1986) (internal citations omitted). Due process “requir[es] the government to follow appropriate procedures when its agents decide to ‘deprive any person of life, liberty, or property.’”Id. The family lies at the heart of civilization, and protecting its privacy and integrity from undue state interference is essential to the maintenance of a free society. Although “the Due Process Clause affords only those protections ‘so rooted in the traditions and conscience of our people as to be ranked as fundamental,’” Michael H. v. Gerald D., 491 U.S. 110, 122 (1989) (plurality opinion) (citing Snyder v. Massachusetts, 291 U.S. 97, 105 (1934)), the Court has “‘long recognized that freedom of personal choice in matters of marriage and family life is one of the liberties protected by the Due Process Clause of the Fourteenth Amendment.’” Moorev. City of E. Cleveland, 431 U.S. 494, 499 (1977) (quoting Cleveland Bd. of Educ.v. LaFleur, 414 U.S. 632, 639-40 (1974)).Accord Loving v. Virginia, 388 U.S. 1, 7 (1967), andSkinner v. Oklahoma ex rel. Williamson, 316 U.S. 535, 541 (1942). In Moore, the Court explained: the Constitution protects the sanctity of the family precisely because the institution of the family is deeply rooted in this Nation’s history and tradition. It is through the family that we inculcate and pass down many of our most cherished values, moral and cultural 431 U.S. at 503-04 (footnote omitted). See also Michael H., 491 U.S. at 123 (noting the “historic respect – indeed, sanctity . . . traditionally accorded to the relationships that develop within the unitary family.”). Thus, in Meyer v. Nebraska, the Court determined that liberty “denotes not merely freedom from bodily restraint but also the right of the individual to . . . establish a home and bring up children . . . and generally to enjoy those privileges long recognized at common law as essential to the orderly pursuit of happiness by free men.” 262 U.S. 390, 399 (1923). Accord Wisconsinv. Yoder, 406 U.S. 205, 233 (1972). As a plurality of this Court has more recently explained, the “liberty interest at issue . . . – the interest of parents in the care, custody, and control of their children – is perhaps the oldest of the fundamental liberty interests recognized by this Court.” Troxel, 530 U.S. at 65 (O’Connor, J.). Similarly, in Meyer, the Court explained that “this [family] liberty may not be interfered with, under the guise of protecting the public interest” and held that parents have a fundamental right to control the education of their children. 262 U.S. at 399-400. “It is cardinal with us that the custody, care and nurture of the child reside first in the parents. . . . [for which reason this Court has] respected the private realm of family life which the state cannot enter.” Prince v. Massachusetts, 321 U.S. 158, 166 (1944) (internal citation omitted). Therefore “it cannot now be doubted that the Due Process Clause of the Fourteenth Amendment protects the fundamental right of parents to make decisions concerning the care, custody, and control of their children.”Troxel, 530 U.S. at 66 (plurality opinion). ”). See . Watkins v. Nelson, 163 N.J. 235, 245 (2000); V.C., supra, 163 N.J. at 217-18; In re Guardianship of K.H.O., 161 N.J. 337, 346 (1999). The public policy and social goal of New Jersey Family Courts to encourage higher education offends the fundamental rights of a select class of parents to control their child’s education. A Florida appellate court in 1978 declined to order a divorced parent to pay for his adult emancipated daughter’s undergraduate college tuition: We agree that a trial court may not order post-majority support simply because the child is in college and the divorced parent can afford to pay. [citations omitted] While most parents willingly assist their adult children in obtaining a higher education that is increasingly necessary in today’s fast changing world, any duty to do so is a moral rather than a legal one. Parents who remain married while their children attend college may continue supporting their children even beyond age twenty-one, but such support may be conditional or may be withdrawn at any time, and no one may bring an action to enforce continued payments. It would be fundamentally unfair for courts to enforce these moral obligations of support only against divorced parents while other parents may do as they choose. Grapin v. Grapin, 450 So.2d 853, 854 (Fla. 1984). Hence, this Court followed the constitutional mandate that forbids interference with family liberty, and that parents have a fundamental right to control the education of their adult children. Indeed the relationship between a minor child and school authorities is not voluntary one, but is compelled by law; a minor child must attend school and is subject to school rules and disciplines; in turn school authorities are obligated to take reasonable precautions for his safety and well-being. Jackson v. Hankinson, 51 N.J. 230, 238 A.2d 685 (1968). N.J.S.A.18A:38-25 provides that every parent, guardian or other person having custody and control of a child between the ages of six and 16 years shall cause such child regularly to attend the public schools of the district or a day school in which there is given instruction equivalent to that provided in the public schools for children of similar grades and attainments or to receive equivalent instruction elsewhere than at school. The law is applied evenhandedly to all New Jersey parents, not just a select class of parents. A parent’s legal obligation to educate their child in New Jersey, terminates upon attaining the age of 16. It would be fundamentally unfair for the State to continue to inject itself into the private realm of only divorcing and noncustodial parents, granting immunity to intake families and questioning the ability of a select class of parents to make the best decisions concerning college educational choices of that parent’s adult children. B. Family Integrity May Not Be Abridged Without Due Process. Due process requires that the State provide adequate procedures and safeguards against the erroneous or arbitrary infringement of protected liberties. Although the right of family and childrearing is fundamental, the Court has recognized that “the rights of parenthood,” like other rights, are not “beyond limitation.” Prince, 321 U.S. at 166. See Stanley v. Illinois, 405 U.S. 645, 649 (1972) (recognizing the “State’s right – indeed, duty – to protect minor children through a judicial determination of their interests in a neglect proceeding.”) The State’s ability to interfere with family integrity is likewise constrained by the Constitution: [S]o long as a parent adequately cares for his or her children (i.e., is fit), there will normally be no reason for the State to inject itself into the private realm of the family to further question the ability of that parent to make the best decisions concerning the rearing of that parent’s children. Troxel, 530 U.S. at 68-69 (plurality opinion). The government may not abridge family integrity without first meeting the high threshold imposed by the Constitution. “[W]hen the government intrudes on choices concerning family living arrangements, the Court must examine carefully the importance of the governmental interests advanced and the extent to which they are served by the challenged regulation. ”Moore, 431 U.S. at 499. In Stanley, the Court cautioned that the interest of “a man in the children he has sired and raised, undeniably warrants deference and, absent a powerful countervailing interest, protection.” 405 U.S. at 651. Where the “issue at stake is the dismemberment of [a] family,” the convenience to a government of a presumption against parental fitness of unwed fathers is “insufficient to justify refusing a father a hearing” prior to deprivation of custody. Id. at 658. See Moriarty v. Bradt, 177 N.J. 84, (2003), discussing in detail that childrearing autonomy is rooted in the right to privacy. Thus: The fundamental liberty interest of natural parents in the care, custody, and management of their child does not evaporate simply because they have not been model parents. . . . Even where blood relationships are strained, parents retain a vital interest in preventing the irretrievable destruction of their family life. Santoskyv. Kramer, 455 U.S. 745, 753 (1982). It is true that a State has a legitimate interest in the creation and dissolution of the marriage contract, see Sosna v. Iowa, 419 U.S. 393, 404 (1975); Maynard v. Hill, 125 U.S. 190, 205 (1888), but the family has a privacy interest in the upbringing and education of children and the intimacies of the marital relationship which is protected by the Constitution against undue state interference, (which clearly exists in New Jersey against a select class of parents, while granting immunity to intact families). In 2000, the Supreme Court cited a long train of previous cases which showed that the right of parents to direct the education and upbringing of their children is a fundamental right. The following passage, taken from Troxel v. Granville, highlights the rich history of this fundamental right: In subsequent cases also, we have recognized the fundamental right of parents to make decisions concerning the care, custody, and control of their children. See, e.g., Stanley v. Illinois, 405 U.S. 645, 651, 92 S.Ct. 1208, 31 L.Ed.2d 551 (1972) ("It is plain that the interest of a parent in the companionship, care, custody, and management of his or her children 'come[s] to this Court with a momentum for respect lacking when appeal is made to liberties which derive merely from shifting economic arrangements'" (citation omitted)); Wisconsin v. Yoder, 406 U.S. 205, 232, 92 S.Ct. 1526, 32 L.Ed.2d 15 (1972) ("The history and culture of Western civilization reflect a strong tradition of parental concern for the nurture and upbringing of their children. This primary role of the parents in the upbringing of their children is now established beyond debate as an enduring American tradition"); Quilloin v. Walcott, 434 U.S. 246, 255, 98 S.Ct. 549, 54 L.Ed.2d 511 (1978) ("We have recognized on numerous occasions that the relationship between parent and child is constitutionally protected"); Parham v. J. R., 442 U.S. 584, 602, 99 S.Ct. 2493, 61 L.Ed.2d 101 (1979) ( "Our jurisprudence historically has reflected Western civilization concepts of the family as a unit with broad parental authority over minor children. Our cases have consistently followed that course"); Santosky v. Kramer, 455 U.S. 745, 753, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982) (discussing "[t]he fundamental liberty interest of natural parents in the care, custody, and management of their child"); Glucksberg, supra, at 720, 117 S.Ct. 2258 ("In a long line of cases, we have held that, in addition to the specific freedoms protected by the Bill of Rights, the 'liberty' specially protected by the Due Process Clause includes the right ... to direct the education and upbringing of one's children" (citing Meyer and Pierce)). In light of this extensive precedent, it cannot now be doubted that the Due Process Clause of the Fourteenth Amendment protects the fundamental right of parents to make decisions concerning the care, custody, and control of their children. (emphasis added) Because fundamental rights are so important to our freedom as Americans, the government must meet a heightened burden of proof in order to restrict those rights. In legal terms, the government's case begins with a positive demonstration – they must prove that there is a government interest in restricting the right, and that the government has a specific interest in restricting the right of the particular parents whose actions are being challenged. In early 2006, the U.S. Supreme Court used this very language when talking about violations of religious liberty. According to the Court, the government must "demonstrate that the compelling interest test is satisfied through application of the challenged law 'to the person'--the particular claimant whose sincere exercise of religion is being substantially burdened." Gonzales v. O Centro Espirito Beneficiente Uniao do Vegetal, 548 U.S. 418, 430-431 (2006). The text of this proposed parental rights amendment merely takes this well-established principle of law, and applies it explicitly to the fundamental right of parents. In 1972, the U.S. Supreme Court held that in order for the state of Wisconsin to override the rights of Amish parents, the government had to show that it had a compelling interest in requiring students to stay in school until age 16. Speaking of the right of the parents, the Court said that "the essence of all that has been said and written on the subject is that only those interests of the highest order and those not otherwise served can overbalance legitimate claims to the free exercise of religion." Wisconsin v. Yoder, 406 U.S. 205, 215 (1972) (emphasis added). The Supreme Court has required the government to follow this standard whenever there is a violation of a fundamental right. Prominent examples of this are cases that deal with racial discrimination (see Adarand v. Pena, 515 U.S. 200, 227 (1995): "All racial classifications, imposed by whatever federal, state, or local governmental actor, must be analyzed by a reviewing court under strict scrutiny. . . . Such classifications are constitutional only if they are narrowly tailored measures that further compelling governmental interests"), restrictions on free speech (see Widmar v. Vincent, 254 U.S. 263, 269-270 (1982): Whenever discriminating against speech on the basis of its content, the government "must show that its regulation is necessary to serve a compelling state interest and that it is narrowly drawn to achieve that end"), and invidious discrimination against religion (see Church of the Lukumi Babalu Aye, Inc., v. Hialeah, 508 U.S. 520, 546 (1993): "To satisfy the commands of the First Amendment, a law restrictive of religious practice must advance 'interests of the highest order' and must be narrowly tailored in pursuit of those interests." In all these cases, the government must prove that it has a compelling interest, before the fundamental freedom at stake can be limited. It is the parents of adult children who have an "important" right concerning the question of whether or not they contribute to the cost of a college education for their adult children and not the State of New Jersey. Moreover, these constitutional rights derive from both privacy rights and liberty interests which have been established. To have laws in New Jersey compelling parents of a selected class to pay for adult child support & secondary higher education is unconstitutional. The decision of parents as to whether or not the adult children should go to college, and who shall pay for those educational expenses are matters of right that are purely personal and moral to the parents and to the adult child. While some parents are willingly assist their adult children in obtaining a higher education that is increasingly necessary in today’s fast changing world, any duty to do so is personal and moral rather than a legal one. Parents who remain married while their children attend college may continue supporting their children even beyond age twenty-one, but such support may be conditional or may be withdrawn at any time, and no one may bring an action to enforce continued payments. It would be fundamentally unfair for New Jersey Courts to continue to enforce these personal and moral obligations of support only against divorced and noncustodial parents while other parents may do as they choose. CONCLUSION The degree to which any parents wishes to support, or discourage, the post majority educational opportunities of adult children is encompassed within the management of children concept. The purpose of “Child Support,” is for the care and maintenance of minor children, not young adults. Therefore upon attending age 18, a child is deemed an adult in the State of New Jersey, and is thereupon possessed of all of the rights, privileges and obligations of adulthood. This includes, voting, entering into financial obligations, securing employment, entering into the Armed Forces for college assistance, obtaining credit, right to decide whether or not to attend college, which college to attend and applying for student loans, being charged with adult crimes in which juvenile court losses jurisdiction. As such, the State of New Jersey has no legitimate interest in interfering with college and adult child support decisions to a select class of parents.
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  238. Between me and my husband we've owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I've settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.
  239. The new Zune browser is surprisingly good, but not as good as the iPod's. It works well, but isn't as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that's not an issue, but if you're planning to browse the web alot from your PMP then the iPod's larger screen and better browser may be important.
  240. Between me and my husband we've owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I've settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.
  241. The new Zune browser is surprisingly good, but not as good as the iPod's. It works well, but isn't as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that's not an issue, but if you're planning to browse the web alot from your PMP then the iPod's larger screen and better browser may be important.
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  243. Hands down, Apple's app store wins by a mile. It's a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I'm not sure I'd want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.
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  246. This is getting a bit more subjective, but I much prefer the Zune Marketplace. The interface is colorful, has more flair, and some cool features like 'Mixview' that let you quickly see related albums, songs, or other users related to what you're listening to. Clicking on one of those will center on that item, and another set of "neighbors" will come into view, allowing you to navigate around exploring by similar artists, songs, or users. Speaking of users, the Zune "Social" is also great fun, letting you find others with shared tastes and becoming friends with them. You then can listen to a playlist created based on an amalgamation of what all your friends are listening to, which is also enjoyable. Those concerned with privacy will be relieved to know you can prevent the public from seeing your personal listening habits if you so choose.
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