Long v. District Court of Iowa, Lee Cty.
Headline: Orders state to provide an indigent prisoner the trial transcript for appealing his habeas corpus denial, barring a fee rule that would block equal access to post-conviction review.
Holding: The Court reversed and held that a State may not require an indigent prisoner to pay for a transcript needed to appeal a denial of a state habeas corpus proceeding.
- Requires states to provide transcripts to indigent prisoners when available for post-conviction appeals.
- Blocks fee-based obstacles that deny equal access to appeal for indigent prisoners.
- Sends cases back to state courts to proceed consistent with this ruling.
Summary
Background
An indigent man convicted of larceny and serving a state prison sentence sought a state habeas corpus hearing in Lee County, Iowa. After an evidentiary hearing at which he had no court-appointed lawyer, the trial court denied relief and refused to provide a free transcript for appeal, saying habeas was a civil action and there was no law requiring a transcript or appointed counsel. The Iowa Supreme Court denied certiorari without opinion, and the man asked this Court to review only the transcript denial.
Reasoning
The narrow question was whether a State may force an indigent prisoner to pay for a transcript needed to appeal a denial in a state-created post-conviction proceeding. Relying on earlier decisions, the Court held that a State may not place a financial obstacle between a poor prisoner and the right to seek review. The opinion noted that a transcript was available and could easily have been furnished, reaffirmed that indigent defendants deserve equal access to appellate review, and reversed the lower judgment.
Real world impact
The ruling means states cannot refuse to provide an available transcript to an indigent prisoner who needs it to appeal a habeas decision. The case was reversed and sent back to the Iowa Supreme Court for further proceedings consistent with this opinion. The Court did not decide situations where a transcript cannot reasonably be made and where alternative procedures would be required.
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