Coppedge v. United States
Headline: Court strengthens indigent defendants’ right to free criminal appeals, ruling lower courts must allow in forma pauperis appeals unless issues are clearly frivolous and remanding a denied appeal for further review, affecting appellate practice.
Holding:
- Makes it easier for poor defendants to appeal without paying court fees.
- Requires appeals courts to appoint counsel and order transcripts when needed.
- Shifts burden to the Government to show an appeal is frivolous.
Summary
Background
A man convicted in federal court sought to appeal without paying costs (called in forma pauperis) because he could not afford them. The District Court denied his request and the Court of Appeals also refused leave to appeal. The Supreme Court agreed to decide what standard lower courts must use when an indigent criminal defendant asks to appeal without prepaying fees.
Reasoning
The Court said that “good faith” must be judged objectively: a defendant shows good faith by seeking review of any issue that is not frivolous. If the papers filed make it clear the defendant will raise a non-frivolous issue, the Court of Appeals should grant leave, appoint counsel, and consider the appeal like any paid appeal. If the application does not make the issues clear, the appeals court must provide counsel and a sufficiently complete record (for example, a transcript) so the defendant can try to show the appeal is not frivolous. The Court emphasized equal treatment for poor litigants, placed the burden on the Government to show frivolity, and expressly did not decide the underlying guilt or innocence of the defendant.
Real world impact
Lower courts must give indigent criminal defendants a realistic chance to develop their appeals before denying fee waivers. Courts may need to order transcripts or appoint counsel earlier in the process. The Supreme Court vacated the appeals court’s denial and remanded for further proceedings, but it left the criminal convictions themselves undecided on the merits.
Dissents or concurrances
One Justice urged that courts might routinely grant pauper appeals and then dismiss frivolous ones after full briefing; two Justices dissented, arguing the Court wrongly shifted the burden and would have disposed of the merits now.
Opinions in this case:
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