96 N.Y.2d 244 (2001)
A support agreement between a mother and a putative father of a nonmarital child is only binding if the court determines that adequate provision has been made for the child’s support, ensuring the child’s needs are met and not contracted away.
Summary
This case addresses whether a father can use Family Court Act § 516 to prevent a mother from seeking more child support when their agreement was court-approved without considering the child’s needs. Clara C. sought additional support from William L. for their child, Thomas, years after a settlement agreement was approved. The Court of Appeals held that William could not bar Clara’s claim because the initial agreement lacked judicial review regarding the adequacy of support for Thomas. The court emphasized the statutory requirement for judicial determination of adequate provision for the child, protecting nonmarital children’s welfare. This decision underscores the importance of judicial oversight in child support agreements to ensure children’s needs are prioritized. The ruling reverses the lower court’s decision, remanding the case for further proceedings.
Facts
In 1983, Clara C. gave birth to Thomas L.C. In 1986, Clara initiated a paternity suit against William L., Thomas’s biological father. Blood tests showed a 99.9% probability of William’s paternity. The parties entered into a settlement agreement under Family Court Act § 516. William agreed to pay $275 monthly until Thomas turned 21 and maintain a life insurance policy. Clara agreed to drop the paternity suit and refrain from future support proceedings if William complied. The Family Court approved the agreement without determining if the support was adequate for Thomas’s needs.
Procedural History
Ten years later, Clara sought a paternity declaration and increased support for Thomas’s education. A Hearing Examiner dismissed the proceeding, citing the § 516 agreement. Family Court appointed a law guardian for Thomas and upheld the dismissal, finding any noncompliance immaterial and the agreement final. The Appellate Division affirmed the Family Court’s decision. Clara appealed to the Court of Appeals.
Issue(s)
Whether a putative father can invoke Family Court Act § 516 to bar a mother from seeking additional child support when the initial support agreement was approved by the court without a determination of whether adequate provision had been made for the child’s needs.
Holding
Yes, because Family Court Act § 516 requires a court to determine that adequate provision has been made for the child’s support before a support agreement is binding, and in this case, the Family Court failed to make such a determination.
Court’s Reasoning
The Court of Appeals held that Family Court Act § 516 requires judicial review and a determination of adequacy for child support agreements to be binding. The statute’s language explicitly states that an agreement is binding “only when the court determines that adequate provision has been made.” The purpose of this requirement is to protect the welfare of nonmarital children, ensuring their needs are adequately met. The court stated that absent judicial review and approval, the agreement will not be enforced to preclude a later modification of support. In this case, the Family Court’s approval was perfunctory, with no consideration of the parties’ financial situation or Thomas’s needs. The court emphasized that Clara’s failure to object earlier does not validate an agreement that lacked the required judicial determination of adequacy. Because the agreement failed to comply with § 516, William could not bar Clara’s petition for increased support. The Court did not rule on the constitutionality of § 516. A concurring opinion argued that § 516, as applied, violates equal protection because it treats nonmarital children differently from marital children regarding support rights, but the majority found it unnecessary to reach the constitutional question given the statutory grounds for the decision.