McCrary v. Indiana
Headline: Court vacates Indiana dismissal and sends case back to decide whether an indigent defendant was denied equal access when he couldn't pay for a trial transcript and the public defender declined help.
Holding:
- Requires state courts to reconsider appeals when indigent defendants lack paid transcripts.
- Pushes courts and defenders to address transcript access for people who cannot pay.
Summary
Background
A man who had sought post-conviction relief in Indiana tried to appeal the denial of that relief to the Indiana Supreme Court. That court dismissed his appeal because he did not follow filing rules that required a trial transcript. He says he could not afford the transcript and that the Indiana Public Defender, who can arrange transcripts for people without money, refused to help. He relied on a prior case, Griffin v. Illinois, to say this raised an equal-access issue.
Reasoning
The central question was whether the Indiana Supreme Court had been told about, and had addressed, his claim that lack of money and refusal of the public defender denied him equal access to the appeals process. The U.S. Court granted permission to proceed without fees, agreed to review the situation, vacated the state court’s dismissal, and sent the case back to Indiana for further consideration of those specific allegations in light of Griffin v. Illinois.
Real world impact
Because the U.S. Court sent the case back, the Indiana court must now examine whether the man’s inability to pay for a transcript and the claimed refusal to assist were raised and properly considered. This ruling does not decide the final merits of his claim; it only requires the state court to reconsider the appeal with those facts in mind. The case returns to the state process for further action.
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