Roberts v. LaVallee

Background

A poor defendant was charged with robbery, larceny, and assault in New York and asked the trial court to provide, at state expense, the transcript (minutes) of a prior preliminary hearing where key witnesses testified. New York law required payment for such transcripts, the trial court denied a free copy, and the defendant was convicted and sentenced. State appeals failed, a federal habeas petition was denied, and then New York’s highest court declared that charging indigents for preliminary hearing transcripts violated equal protection.

Reasoning

The central question was whether refusing a free preliminary hearing transcript to an impoverished defendant violates the Constitution and whether federal courts should insist on additional state proceedings first. The Court relied on prior decisions rejecting financial barriers to legal rights and concluded the New York fee rule could not stand as applied to an indigent. The Court also found the defendant had already exhausted state remedies and that further state litigation would be unnecessary and burdensome. The Court vacated the lower judgment and sent the case back for proceedings consistent with this opinion.

Real world impact

The decision means poor criminal defendants cannot be required to pay for preliminary hearing transcripts when those transcripts are necessary to vindicate their rights, and federal courts may provide relief when state remedies are already exhausted and further state action would be pointless. The ruling requires states to revise practices that place financial barriers between indigent defendants and important trial materials.

Dissents or concurrances

Justice Harlan dissented, arguing the record showed the defendant and counsel had attended the hearing, that a grand jury transcript was provided, and that there was no demonstration the preliminary transcript would have mattered; he would have required a hearing on actual prejudice before setting aside the conviction.