434 U.S. 246 (1978)
The child at the center of this dispute was born in December 1964 to Ardell Williams Walcott and Leon Webster Quilloin.1 The parents never married each other or established a home together, and the mother maintained custody and control of the child for his entire life.2 In September 1967 the mother married Randall Walcott, after which the child moved in with the couple in 1969.3
In March 1976 Ardell Walcott consented to adoption of the child by her husband.4 Randall Walcott immediately filed a petition for adoption in the Superior Court of Fulton County.5 Leon Quilloin responded by filing an application for a writ of habeas corpus to obtain visitation rights, a petition for legitimation of the child, and an objection to the adoption; he subsequently amended his pleadings to include constitutional challenges.6
The trial court consolidated the adoption, legitimation, and habeas corpus matters for hearing and received extensive testimony from the parties and other witnesses.7 Evidence showed that Quilloin had provided support only on an irregular basis over the years and that the child had visited him on many occasions until the mother concluded the contacts were disruptive.8 The child expressed a desire to be adopted by Randall Walcott and to take his name, and the court found Walcott to be a fit and proper person to adopt.9
On the basis of these facts the trial court determined that the adoption was in the best interests of the child, denied the petitions for legitimation and visitation, and granted the adoption because Quilloin had not obtained a legitimation order.10 Quilloin appealed to the Supreme Court of Georgia, which affirmed the trial court's decision.11 He then brought the case to the United States Supreme Court, which noted probable jurisdiction in 1977.12
Whether Georgia's adoption laws as applied to an unwed father violate the Due Process Clause by permitting denial of veto authority over adoption based on a best-interests-of-the-child standard rather than a finding of unfitness?13
The Due Process Clause protects the parent-child relationship as a liberty interest.14 An unwed father who has never sought or exercised actual or legal custody over the child presents a different situation.15 In such circumstances, where the proposed adoption recognizes an existing family unit already functioning as such, the State satisfies due process by applying a best-interests-of-the-child standard without requiring a separate finding of parental unfitness.16
No. Although the relationship between parent and child is constitutionally protected, this is not a case in which the unwed father at any time had, or sought, actual or legal custody of his child.17 Nor is this a case in which the proposed adoption would place the child with a new set of parents with whom the child had never before lived. Rather, the result of the adoption in this case is to give full recognition to a family unit already in existence, a result desired by all concerned, except appellant. Whatever might be required in other situations, we cannot say that the State was required in this situation to find anything more than that the adoption, and denial of legitimation, were in the “best interests of the child.
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Georgia's adoption laws as applied did not violate the Due Process Clause.18
Whether Georgia's adoption laws as applied to an unwed father violate the Equal Protection Clause by providing less authority to veto an adoption than is afforded to married fathers?19
The Equal Protection Clause permits a State to afford an unwed father who has never exercised actual or legal custody less veto authority over adoption than it affords a married father.20 The two classes are not similarly situated with respect to the extent of prior commitment to the child's daily care and supervision.21
No. Although Quilloin was subject to the same support obligation as a married father, he never exercised actual or legal custody over the child and thus never shouldered significant responsibility for the daily supervision, education, protection, or care of the child.22 In contrast, legal custody is a central aspect of the marital relationship, and even a father whose marriage has broken apart will have borne full responsibility for rearing his children during the period of the marriage.23 The State could therefore recognize this difference in the extent of commitment to the welfare of the child without violating equal protection.24
Georgia's adoption laws as applied did not violate the Equal Protection Clause.25