Eskridge v. Washington State Board of Prison Terms & Paroles
Headline: Court reverses Washington and requires free trial transcripts when necessary so indigent defendants can obtain equal appellate review, ensuring poor people are not blocked from appeals for lack of money.
Holding: The Court held that Washington denied the Fourteenth Amendment rights of an indigent defendant by refusing a free trial transcript necessary for an effective appeal, reversed the state court, and remanded for further proceedings.
- Requires states to provide necessary trial records for effective appeals by indigent defendants.
- Stops states from limiting appeals to defendants who can afford transcripts.
- May force state courts to reopen or continue appeals where records were denied.
Summary
Background
A man convicted of murder in Washington in 1935 sought to appeal but was indigent and asked the trial judge for a free stenographic transcript. Washington law allowed a judge to order a free transcript if the judge thought justice would be promoted, but the trial judge denied the request. The State Supreme Court then dismissed the appeal for lack of a certified transcript. In 1956 the man filed a state habeas petition claiming denial of due process and equal protection; the state courts denied relief and the U.S. Supreme Court took the case. The State did not dispute his poverty, the existence of substantial trial errors he alleged, or his need for a record to pursue the appeal.
Reasoning
The Court addressed whether a State violates the Fourteenth Amendment by allowing appellate review for defendants who can pay for trial records while denying that review to those who cannot. Relying on Griffin v. Illinois, the Court held Washington’s refusal to furnish a transcript here denied the indigent defendant adequate appellate review. The trial judge’s declaration that no reversible error occurred could not replace a full record on appeal. The Court clarified it did not require free transcripts in every indigent case, only that poor defendants be afforded as adequate appellate review as those who can pay.
Real world impact
The decision requires states to provide trial records when a defendant’s poverty would otherwise block meaningful appellate review. State courts must decide when a transcript is necessary for an effective appeal and provide it if so. The Washington Supreme Court’s judgment was reversed and the case sent back for further proceedings consistent with this ruling.
Dissents or concurrances
Two Justices (Harlan and Whittaker) said Griffin should not apply to a 1935 conviction and would have affirmed; one Justice (Frankfurter) did not participate.
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