Mario Lalli called Robert "my son" in a notarized paper, and the Supreme Court still let New York shut him out of the estate

Mario Lalli died in New York on 7 January 1973 without a will. His widow, Rosamond Lalli, became administratrix. Robert Lalli said he was Mario's son, born outside marriage, and asked for an accounting of the estate. He offered a notarized form in which Mario consented to Robert's marriage and called him "my son", and sworn statements that Mario openly acknowledged him. New York's Estates, Powers and Trusts Law section 4-1.2 let such a child inherit from a father only if a court had issued an order of filiation during the father's life. Robert had none. The Surrogate's Court excluded him and the New York Court of Appeals agreed. The U.S. Supreme Court sent the case back after Trimble v. Gordon, and New York upheld the statute again. On 11 December 1978 the Supreme Court affirmed, 5 to 4. Justice Powell wrote that the rule was "an evidentiary one" serving the orderly settlement of estates. Justice Brennan, dissenting, wrote that it made it "virtually impossible for acknowledged and freely supported illegitimate children to inherit." In 2026 the same New York section lets a child inherit from a father when parentage is proved by clear and convincing evidence, including a genetic marker test or proof that the father "openly and notoriously" acknowledged the child.