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M.L.B. v. S.L.J.
No. 95-853 (U.S. Dec. 16, 1996). ; Clearinghouse Number: 52214
Description
Supreme Court Holds That State May Not Refuse to Pay for Transcript in Appeal of Termination of Indigent Mother's Parental Rights
Abstract
The Supreme Court has held that the state of Mississippi may not
deny an indigent mother, because of her poverty, appellate review
of the sufficiency of the evidence on which the trial court based
its decision to terminate mother's parental rights. After the
trial court terminated petitioner mother's parental rights, she
sought to appeal. However, state law conditioned her right to
appeal on the prepayment of transcript fees estimated at $2,352.
Mother's petition to proceed in forma pauperis was denied, and
she appealed. Citing Griffin v. Illinois, 351 U.S. 12, and Boddie
v. Connecticut, 401 U.S. 371, the Court held that mother's
parental termination appeal must be treated as the Court has
treated petty offense appeals. Accordingly, the Court held the
state may not withhold from mother the transcript that she needed
to gain review of the order terminating her parental rights. The
court noted that parental status termination is irretrievably
destructive of the most fundamental family relationship and that
the risk of error is considerable. Moreover, the court found that
the state's interest in offsetting the costs to its court
system of providing transcripts to indigent parents was
unimpressive when measured against the stakes for parents subject
to parental rights termination.
