Mayer v. City of Chicago
1971 U.S. LEXIS 298, 404 U.S. 189, 30 L. Ed. 2d 372 (1971)
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Rule of Law:
The Equal Protection and Due Process Clauses of the Fourteenth Amendment require a state to provide an indigent defendant with a trial transcript or a record of sufficient completeness to permit an effective appeal, regardless of whether the offense was a felony or a nonfelony and whether the punishment was imprisonment or only a fine.
Facts:
- The appellant, an indigent medical student, was convicted in Chicago on nonfelony charges of disorderly conduct and interference with a police officer.
- His convictions were for violations of city ordinances.
- He was sentenced to pay a $250 fine for each offense and was not subject to imprisonment.
- The appellant desired to appeal his convictions on the grounds that the evidence was insufficient and that prosecutorial misconduct had denied him a fair trial.
- To support his appeal, he required a transcript of the trial proceedings.
Procedural Posture:
- A jury in the Circuit Court of Cook County, Illinois (a state trial court), convicted the appellant of two nonfelony ordinance violations.
- The appellant petitioned the Circuit Court for a free transcript to support his appeal.
- The Circuit Court found the appellant to be indigent but denied his petition, citing Illinois Supreme Court Rule 607(b), which limited free transcripts to felony cases.
- The appellant then filed a motion directly in the Illinois Supreme Court (the state's highest court) for a free transcript.
- The Illinois Supreme Court denied the motion in an unreported order without an opinion.
- The appellant appealed the Illinois Supreme Court's denial to the Supreme Court of the United States.
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Issue:
Does an Illinois court rule that provides free trial transcripts for appeals only to indigent defendants convicted of felonies, but not to those convicted of nonfelony offenses, violate the Equal Protection and Due Process Clauses of the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Brennan
Yes, the Illinois rule violates the Fourteenth Amendment. The principle established in Griffin v. Illinois—that states must afford indigent defendants appellate review as adequate as that available to defendants with funds—prohibits unreasoned distinctions that impede access to the courts. The distinction between felony and nonfelony offenses is an 'unreasoned distinction' because a defendant's ability to pay bears no rational relationship to their guilt or innocence, regardless of the severity of the crime. Furthermore, the argument that the state's fiscal interest outweighs the defendant's right to appeal when only a fine is imposed is invalid; the Griffin principle is a flat prohibition against pricing indigent defendants out of an effective appeal. Where an appellant makes a colorable claim of need for a transcript, the burden is on the state to show that an alternative, such as an agreed statement of facts, is sufficient.
Concurring - Mr. Chief Justice Burger
Yes, the rule is unconstitutional. However, it is important to emphasize that a full verbatim transcript is not required in most cases and that alternatives are available. Counsel, as officers of the court, have a professional duty to seek only what is necessary for an appeal and to avoid making profligate demands for transcripts at public expense, which can cause significant delays in the appellate process.
Concurring - Mr. Justice Blackmun
Yes, the rule is unconstitutional. It is worth noting, however, that the appellant's indigency status was determined when he was a medical student. On remand, the Illinois courts should consider whether his financial circumstances have changed, as he may have completed his training and may no longer be indigent.
Analysis:
This case significantly extends the constitutional protections established in Griffin v. Illinois, which mandated free transcripts for indigent felons. By applying this principle to nonfelony cases, even those punishable only by a fine, the Court affirmed that equal access to appellate justice is not contingent on the severity of the offense or punishment. The decision also clarified the procedural burden, placing it on the state to prove that a less-than-complete record is adequate once an indigent appellant demonstrates a colorable need for a transcript. This strengthens the appellate rights of indigent defendants across the entire spectrum of criminal and quasi-criminal law.
