Michael H. v. Gerald D., 491 U.S. 110 (1989), was a case decided by the Supreme Court of the United States involving substantive due process in the context of paternity law.

The Court subsequently addressed questions involving the constitutionality of legitimacy laws in Quilloin v. Walcott (1978), Caban v. Mohammed (1979), and Lehr v. Robertson (1983).

[1] According to The Washington Post's Ruth Marcus, the facts of the dispute "more closely resembled a soap opera synopsis than a typical Supreme Court case".

[5] The superior court granted Gerald's motion, rejected challenges by Victoria (represented by a guardian ad litem) and Michael to the law's constitutionality, and denied visitation on the grounds that it would "violat[e] the intention of the Legislature by impugning the integrity of the family unit".

[1] The California Court of Appeal, Second District, affirmed, holding that the law did not violate Michael's rights under the Fourteenth Amendment's Due Process Clause.

[2][6][8] For the plurality, Scalia rejected Michael's argument that he had a procedural-due-process right to be heard regarding his paternity claim, reasoning that the challenged California law was substantive rather than procedural.

Treating Michael's arguments as an invocation of substantive due process, the plurality then concluded that he had no constitutionally protected liberty interest in his relationship with Victoria.

I cannot accept an interpretive method that does such violence to the charter that I am bound by oath to uphold.Brennan argued that under prior precedent, a protected liberty interest was present because Michael and Victoria were biologically connected and had an established relationship.

He concluded that Michael had the same sort of liberty interest as had been recognized in prior cases and that California had deprived him of it without due process of law.