Little v. Streater
1981 U.S. LEXIS 106, 68 L. Ed. 2d 627, 452 U.S. 1 (1981)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment requires a state to pay for blood grouping tests for an indigent defendant in a paternity action when the state is substantially involved in the litigation and the tests are a critical procedural safeguard for a meaningful opportunity to be heard.
Facts:
- Gloria Streater, an unmarried woman, gave birth to a child and began receiving public assistance.
- As a condition of receiving assistance, Streater identified Walter Little to the State of Connecticut as the child's father.
- The State of Connecticut, on behalf of Streater, initiated a paternity suit against Little to establish his liability for child support.
- At the time of the suit, Little was incarcerated and indigent.
- Little requested blood grouping tests, asserting they would prove he was not the father.
- A Connecticut statute required the party moving for such tests to bear the cost, and because Little could not pay, the tests were not performed.
Procedural Posture:
- The State of Connecticut, on behalf of Gloria Streater, sued Walter Little for paternity in the Connecticut Court of Common Pleas, a trial court.
- Little filed a motion for the court to order blood grouping tests at the State's expense, which the trial court denied.
- Following a trial on the merits without blood test evidence, the court found Little to be the father and entered a judgment of support against him.
- Little, as appellant, appealed to the Appellate Session of the Connecticut Superior Court.
- The Appellate Session affirmed the trial court's judgment.
- The Connecticut Supreme Court denied Little's petition for certification.
- The U.S. Supreme Court noted probable jurisdiction to hear the appeal from the Appellate Session of the Connecticut Superior Court.
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Issue:
Does a state statute that requires the party requesting blood grouping tests in a paternity action to pay for them violate the Due Process Clause of the Fourteenth Amendment when applied to deny such tests to an indigent defendant in a state-initiated proceeding?
Opinions:
Majority - Chief Justice Burger
Yes, the state statute as applied to this indigent defendant violates the Due Process Clause. To determine what procedural protections are required, the Court applied the three-factor balancing test from Mathews v. Eldridge. First, the private interests at stake are substantial, involving not only a significant financial obligation but also the creation of a constitutionally protected parent-child relationship. Second, the risk of an erroneous deprivation is high in paternity cases that often rely on conflicting testimony, and this risk is uniquely heightened by a Connecticut evidentiary rule that makes a mother's consistent accusation prima facie evidence of paternity that cannot be overcome by the defendant's testimony alone; blood tests are a highly reliable and often conclusive procedural safeguard. Third, the government's interest is primarily financial, which is weakened by the availability of 75% federal reimbursement for such costs and is insufficient to overcome the significant private interests and the need for an accurate determination. Given the State's deep involvement in the litigation and the fundamental interests at stake, denying Little access to this crucial exculpatory evidence denied him a meaningful opportunity to be heard, in violation of fundamental fairness.
Analysis:
This decision extends the due process protections established in cases like Boddie v. Connecticut to indigent defendants in quasi-criminal civil proceedings initiated by the state. It establishes that when the state acts as the adversary and fundamental familial rights are at stake, it cannot use a party's poverty to deny them access to critical, and potentially dispositive, scientific evidence. The ruling solidifies the principle that a 'meaningful opportunity to be heard' requires not just access to the courts, but also the essential tools for a competent defense, thereby influencing how states handle paternity and other civil suits involving indigent defendants.
