Roberts v. LaVallee
389 U.S. 40, 19 L. Ed. 2d 41, 1967 U.S. LEXIS 436 (1967)
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Rule of Law:
Under the Equal Protection Clause, a state must provide an indigent criminal defendant with a free transcript of a preliminary hearing if such a transcript is available to non-indigent defendants for a fee.
Facts:
- Petitioner, an indigent individual, was charged with robbery, larceny, and assault in a New York court.
- A preliminary hearing was held where the major witnesses for the state provided testimony.
- When Petitioner's case was called for trial, he requested that the court provide him, at state expense, with a transcript of the prior preliminary hearing.
- A New York statute made such transcripts available to any defendant upon payment of a fee.
- The trial court denied Petitioner's request for a free transcript due to his inability to pay the required fee.
Procedural Posture:
- Petitioner was convicted in a New York state trial court after his request for a free preliminary hearing transcript was denied.
- The Appellate Division of the New York Supreme Court, an intermediate appellate court, affirmed his conviction.
- The New York Court of Appeals, the state's highest court, denied leave to appeal.
- Petitioner filed a petition for a writ of habeas corpus in the U.S. District Court for the Northern District of New York, which was denied.
- Petitioner, as appellant, appealed to the U.S. Court of Appeals for the Second Circuit, which dismissed the petition without prejudice, ordering him to seek relief in state courts.
- Petitioner sought a writ of certiorari from the U.S. Supreme Court to review the judgment of the Court of Appeals.
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Issue:
Does denying an indigent criminal defendant a free transcript of a preliminary hearing, when such a transcript is available for a fee to other defendants, violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Per Curiam
Yes. Denying an indigent defendant access to instruments needed to vindicate legal rights based on their financial situation violates the Equal Protection Clause. For over a decade, the Court's decisions, such as Griffin v. Illinois and Draper v. Washington, have established that 'to interpose any financial consideration between an indigent prisoner of the State and his exercise of a state right to sue for his liberty is to deny that prisoner the equal protection of the laws.' The New York statute, by requiring a fee that prevented the petitioner from obtaining a transcript available to others, clearly could not meet this constitutional test. Furthermore, the petitioner had already exhausted his state remedies, and requiring him to return to state court after a favorable state ruling in another case would be a 'repetitious application' contrary to the principles of federal habeas corpus established in Brown v. Allen.
Dissenting - Harlan
No, a state is not automatically required to supply any document free to an indigent just because it is available for a fee; the court should first examine the document's importance and whether the denial caused prejudice. The majority's 'undiscriminating rule' could lead states to narrow the availability of such documents for all defendants. In this case, the petitioner was present at the hearing, received a free transcript of the grand jury testimony from the same witness, and never specified any use for the preliminary hearing transcript. Additionally, since state law now provided a basis for relief, the federal court should have abstained to allow the state court to resolve the matter. At a minimum, the case should have been remanded to determine if the error was 'harmless beyond a reasonable doubt' before setting aside a state conviction.
Analysis:
This case solidifies and extends the principle from Griffin v. Illinois, which prohibits wealth-based discrimination in the criminal justice system. By specifically applying this rule to preliminary hearing transcripts, the Court affirmed their importance as a tool for an effective defense. The decision also provides important clarification on the federal habeas corpus exhaustion doctrine, establishing that a petitioner who has fairly presented a claim to state courts need not re-litigate it there, even if the state's own law subsequently changes to favor their position. This strengthens the power of federal courts to promptly vindicate federal constitutional rights without undue or repetitive deference to state procedure.
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