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Little v. Streater

Supreme Court of the United States · 1981 · Constitutional Law

Constitutional LawDue ProcessPaternity ProceedingsIndigencyFourteenth AmendmentDue Process Clausemeaningful opportunity to be heardMathews v. Eldridge

Facts

After appellee's child received public assistance, Connecticut required appellee to identify the putative father and provided counsel to bring a paternity suit against appellant Walter Little. Little, an indigent prisoner represented by legal aid counsel, moved for blood grouping tests and asked that the State pay for them under Connecticut's statute authorizing such tests but charging their cost to the requesting party. The trial court authorized the tests but refused to require state payment, so no tests were performed for financial reasons. Connecticut law also gave evidentiary weight to the mother's constant accusation and required the defendant to show innocence by evidence other than his own testimony; Little was adjudged the father and ordered to pay support and related sums.

Issue

Whether Connecticut violates the Due Process Clause of the Fourteenth Amendment by applying its statute requiring the requesting party to pay for blood grouping tests so as to deny those tests to an indigent defendant in a paternity action. More specifically, the question is whether, in the circumstances of this state-involved paternity proceeding, denial of state-funded blood tests deprived the defendant of a meaningful opportunity to be heard.

Rule

Due process requires, at minimum, that absent a countervailing state interest of overriding significance, persons forced to settle claims of right and duty through the judicial process must be given a meaningful opportunity to be heard. In determining what process is due, courts apply the Mathews v. Eldridge factors: the private interests at stake, the risk of erroneous deprivation under existing procedures and the probable value of additional safeguards, and the government's interests and burdens. A facially valid cost requirement violates due process as applied when, in the particular circumstances, it forecloses an indigent party's meaningful opportunity to present highly probative exculpatory evidence.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Milwaukee, a child receiving public assistance leads Wisconsin's family support unit to require the mother, Elena Ruiz, to identify a putative father under oath. The State pays Elena's lawyer, joins the case, and will collect any support ordered. Marcus Bell, an indigent defendant, asks for state-funded blood-grouping tests that could exclude him, but a statute requires the requesting party to prepay for the tests.

Under the majority's due process analysis, which result is most likely?

Explanation. Due process is assessed under Mathews v. Eldridge and the meaningful-opportunity-to-be-heard principle. Where the State is heavily involved in the paternity action, the defendant is indigent, and the requested blood tests have unique exculpatory value because they can definitively exclude many falsely accused men, denying access solely for inability to pay is fundamentally unfair. The majority emphasized that the holding is as applied, not a facial invalidation, and that the civil label does not control where the proceeding has serious consequences and quasi-criminal overtones.