| M.L.B. v. S.L.J. | ||||||
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Supreme Court of the United States |
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| Argued October 7, 1996 Decided December 16, 1996 |
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| Full case name | M. L. B. v. S. L. J., individually and as next friend of the minor children, S. L. J. and M. L. J., et ux. | |||||
| Docket nos. | 95-853 | |||||
| Citations | U.S. [1] (more) 519 U.S. 102 |
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| Prior history | Griffin v. Illinois, Mayer v. Chicago | |||||
| Argument | Oral argument | |||||
| Reargument | Reargument | |||||
| Opinion Announcment | Opinion announcement | |||||
| Holding | ||||||
| Just as a State may not block an indigent petty offender's access to an appeal afforded others, see Mayer v. Chicago, 404 U.S. 189, 195-196, so Mississippi may not deny M. L. B., because of her poverty, appellate review of the sufficiency of the evidence on which the trial court based its parental termination decree. | ||||||
| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Ginsburg, R., joined by O'Connor, S., Breyer, S., Souter, D., and Stevens, J. | |||||
| Concurrence | Kennedy, A. | |||||
| Dissent | Thomas, C. joined by Rehnquist, W., joined by Scalia, A. | |||||
M.L.B. v. S.L.J., 519 U.S. 102 (1996), was a court case brought to the United States Supreme Court regarding a controversy over the Fourteenth Amendment. The Petitioner M.L.B. argued that the Mississippi Chancery Courts could not terminate her parental rights on the basis that she was unable to pay the court fees. M.L.B. had been sued by S.L.J. in order to terminate M.L.B.'s parental rights and gain the ability to adopt the children. The judge declared in favor of S.L.J. under the premise their decree was fair as it was based on the father’s and the father’s second wife’s fulfilling of the burden of proof through “clear and convincing evidence.”.[1] Despite this statement, the Court never elaborated on this evidence or clearly explained why M.L.B.’s parental rights had been dismissed. When M.L.B. went to appeal, she was unable to pay for the record preparation fees of $2,352.36 and was denied. She then went to appeal under forma pauperis, but was again denied on the grounds that forma pauperis is only demanded in criminal, and not civil, cases. The case was then brought to the United States Supreme Court where M.L.B. held that an inability to pay court fees should not be decisive of something as precious as parental rights. She used the guidelines set out in the Due Process and Equal Protection clauses of the Fourteenth Amendment to fight her case. The Supreme Court decided in the Petitioner’s favor and stated that in matters regarding parental rights a court may not stop a party from appealing their case based on financial means.
Because this ruling extended forma pauperis to civil cases, there was a question of how liberally it could be applied. It was then clarified that forma pauperis may only be applied to civil cases where state controls or intrusions on family relationships are involved.[2] The Court decided to rule this way as the family unit is considered so fundamental that its liberty interests should be protected by the Fourteenth Amendment. If these appellate rights weren’t protected, it was proposed to be as devastating as if a criminal’s appellate rights were not considered.
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On November 15, 1993, respondent S.L.J., and biological father of the children, sued petitioner M.L.B., their biological mother, in a Mississippi Chancery Court for adoptive rights of the petitioner’s natural children. After a three day trial, the court decided in favor of S.L.J.. M.L.B. filed for an appeal where she intended to argue that the Court’s decision was unsupported by the evidence, or lack thereof. The fees the Court charged her for the record preparations was too high for the petitioner to pay and, determined to keep her parental rights, she asked for forma pauperis. When she went to the Mississippi Supreme Court, M.L.B.’s motions were denied, but on April 1, 1996 the United States Supreme Court agreed to hear the petitioner’s case through writ of certiorari. M.L.B. went into the case ready to back her stance through the Fourteenth Amendment. In section 1 of the Fourteenth Amendment it is stated “No state shall… deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”.[1] When making their decision, the Supreme Court also took into account many cases that were related to issues with the Fourteenth Amendment. They looked at Griffin v. Illinois in which it was decided that if an appeal was granted, the indigent defendants must be granted the same level of appellate review as defendants that could afford every record or transcript. They considered Mayer v. Chicago where a destitute criminal’s right to appeal was upheld again. This case came at time where the need for such changes in the law was growing. The Justices also took into account cases where the family was involved. Lassiter v. Department of Social Servs. of Durham Cty., 452 U.S. 18, where it was stated that indigent defendants in a parental termination case are not required by the Constitution to be provided with counsel, but it should be determined by the circumstances. In the 1990s, the divorce rate was in the high 40%.[3] In 1993, the year of the original case, the poverty rate was at 15.1% and there were 39.3 million people living beneath the official poverty level.[4] Although the window this case opened for forma pauperis in civil cases was narrow, it was also highly necessary.
When M.L.B. was unable to appeal due to her financial difficulties, she felt that forma pauperis should at least apply. Forma pauperis could not, however, apply to an issue such as parenthood because it was reserved exclusively for criminal cases. The conflict then arose of whether or not a state, consistent with the Fourteenth Amendment of the Constitution, could condition appeals made by indigent persons when a court decrees termination of parental rights. The court was reluctant to extend forma pauperis to any civil case as it may open the door for too many petty civil cases to apply. When making their decision, the Supreme Court looked at this one situation and considered family a fundamental right of a citizen.
In a 6-3 opinion of the Supreme Court, it was decided that “just as a state may not block an indigent petty offender's access to an appeal afforded others, so Mississippi may not deny M.L.B., because of her poverty, appellate review of the sufficiency of the evidence on which the trial court found her unfit to remain a parent.”.[1] The court stated that due process could not be halted by a lack of funds in a case where the termination of parental rights is at risk. Ruth Ginsburg wrote the majority opinion and was joined by O’Connor, Souter, Breyer, and Stevens. The concurrence was written by Anthony Kennedy. A case that contributed to the Court’s opinion was Griffin v. Illinois, 351 U.S. 12 (1956). Before this case was fought, only convicted felons sentenced to death would have access to an appellate review regardless of their ability to pay for transcripts. The court then decided that all criminal cases would be allowed the same right in accordance with the Fourteenth Amendment. The other largely influential case on M.L.B. v. S.L.J. was Mayer v. Chicago, 404 U.S. 189 (1971). Through this case, it was determined that any offence, even “quasi-criminal” in nature may be appealed regardless of financial means.[1] M.L.B. argued that what was at stake for her was far greater than what was at stake for a “quasi-criminal” and her right to appeal should in no way be determined by her wallet. The court made their ruling based on this argument and reversed the one made by the Mississipi Supreme Court.
The concurrence was written by Justice Kennedy. In it he reiterates the impact that both Griffin v. Illinois and Mayer v. Chicago had on the case. He also goes on to say that they must reverse the previous ruling, due to the importance of the rights inherent in any family related matters. Although it is understood that appellate review is not always necessary, if it is granted the Court must not bar a litigant from fulfilling their appeal due to a lack of funds in cases as grave as M.L.B. v. S.L.J.. In matters regarding the family, Kennedy cites cases like Boddie v. Connecticut and Lassiter v. Department of Social Servs. of Durham Cty. as grounds for their decision.[1]
The dissenting opinion was written by Justice Clarence Thomas and was joined by Rehnquist and Scalia. In it, they contend that if they allow for free transcripts in a civil appeal in this one case, then it will be applied too liberally to other civil cases. There is also issue over M.L.B.’s claims that she should be protected under Due Process and Equal Protection Clauses as there is no clear explanation how they apply. They go on to say that nowhere in the Due Process clause is a state even obliged to provide for an appeal.[1] The dissenting opinion has issue with the fact that the petitioner has gone through an entire court process that was provided for her ensuring her due process. They believe that the state’s duty to M.L.B. has been fulfilled. The dissenting Justices question M.L.B.’s motives, as well, stating that the petitioner may care less about her due process and more about delaying the sting of termination of her parental rights. The Supreme Court rulings cited in the majority’s opinion are deemed as irrelevant as they apply to criminal, and not civil, cases.
M.L.B. v. S.L.J. was a ruling fit for its time. This case now opened the doors for destitute men and women to fight for their parental rights. During the 1990s, poverty levels hit remarkable lows and divorce ratse remained high.