Griffin v. Illinois

Supreme Court of United States
351 U.S. 12 (1956)

ELI5:

Rule of Law:

If a state provides a right to appellate review, the Due Process and Equal Protection Clauses of the Fourteenth Amendment require the state to provide indigent criminal defendants with a trial transcript or its equivalent, free of charge, if it is necessary for an adequate and effective appeal.

Facts:

Griffin and Crenshaw were convicted of armed robbery in the Criminal Court of Cook County, Illinois.
Under Illinois law, a full direct appellate review of alleged trial errors required the defendant to furnish the appellate court with a bill of exceptions or a report of the trial proceedings.
In many cases, it was impossible to prepare an adequate bill of exceptions without a stenographic transcript of the trial.
Griffin and Crenshaw were indigent and alleged they had no means of paying the necessary fees to acquire the transcript and court records.
Illinois law at the time provided free transcripts only for indigent defendants sentenced to death, not for those convicted of other felonies.
Due to their inability to pay for a transcript, Griffin and Crenshaw were unable to obtain a full appellate review of their alleged, non-constitutional trial errors.

Procedural Posture:

Griffin and Crenshaw were convicted of armed robbery in the Criminal Court of Cook County, Illinois, a state trial court.
Immediately following their conviction, they filed a motion in the trial court for a free certified copy of the entire record, including the transcript. The trial court denied the motion.
Griffin and Crenshaw then filed a petition under the Illinois Post-Conviction Hearing Act, which was dismissed by the trial court without a hearing.
The Supreme Court of Illinois, the state's highest court, affirmed the dismissal, holding that the petitioners' claims raised no substantial state or federal constitutional questions.
The petitioners, Griffin and Crenshaw, sought and were granted a writ of certiorari from the U.S. Supreme Court.

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Issue:

Does Illinois's practice of granting appellate review to all criminal defendants but denying free trial transcripts necessary for that review to indigent defendants, except in capital cases, violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment?

Opinions:

Majority - Justice Black

Yes. A state's refusal to provide indigent defendants with the necessary trial transcripts for a full appellate review, while granting such review to all who can afford it, is a violation of the Due Process and Equal Protection Clauses. While a state is not constitutionally required to provide a right to appeal, once it does so, it cannot administer that right in a way that discriminates based on wealth. Such a practice creates an 'invidious discrimination' because the ability to pay for a transcript bears no rational relationship to a defendant's guilt or innocence. Denying the poor an adequate appellate review is functionally equivalent to denying them the right to defend themselves at trial, rendering the promise of a fair trial meaningless for them.

Concurring - Justice Frankfurter

Yes. While states have broad discretion in crafting their appellate procedures, they cannot create a system that effectively forecloses appellate review for indigent persons. To make the ability to appeal contingent on wealth is a 'squalid discrimination' that violates the core principles of equal justice. When a state deems appellate review wise and just, it cannot erect a financial barrier that disables the poor from securing such a review. However, the state can implement measures to prevent frivolous appeals and may find alternative, economical means besides a full transcript to ensure effective review.

Dissenting - Justice Burton

No. The Constitution does not compel a state to equalize the economic circumstances of all defendants. The Illinois law does not deny equal protection because the distinction between capital and non-capital cases is a reasonable one, given the finality of the death penalty. The terms of appeal are open to all, and the state is not responsible for an individual's inability to pay. Imposing this requirement on states is an interference with their power to manage their own judicial systems, a field of local option.

Dissenting - Justice Harlan

No. The Court's holding incorrectly frames the issue as one of Equal Protection when it is better analyzed under Due Process, and it fails that test as well. The Equal Protection Clause does not impose an affirmative duty on states to lift the handicaps of poverty. All Illinois has done is fail to alleviate economic differences that exist apart from any state action. Under a Due Process analysis, Illinois's system is not arbitrary or capricious; a policy of economy is not unconstitutional. The state's failure to provide free transcripts to all indigent defendants is not a 'denial of fundamental fairness, shocking to the universal sense of justice.'

Analysis:

Griffin v. Illinois is a landmark case that significantly expanded the rights of indigent criminal defendants. It established that the Equal Protection and Due Process Clauses require states to ensure that poverty does not become a barrier to accessing the appellate process. This decision created an affirmative obligation on the state to provide resources, like transcripts, to level the playing field, moving beyond merely prohibiting explicit discrimination. The principle established in Griffin laid the essential groundwork for subsequent decisions that guaranteed other rights to indigent defendants, most notably the right to counsel on a first appeal in Douglas v. California.

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