Little v. Streater

Background

An unmarried mother receiving public assistance identified a jailed, low-income man as the child’s father and the State referred the paternity suit for prosecution. Connecticut law allowed courts to order blood grouping tests but said the party requesting them must pay. The trial court authorized tests but refused to have the State pay; no tests were done for “financial reasons,” the court then found the man to be the father and entered a support judgment against him.

Reasoning

The Court examined whether denying state-funded blood tests to an indigent defendant in a paternity case violated the Due Process Clause. It applied the Mathews balancing test: the man’s private interests were substantial (avoiding a parental status and support obligations, and liberty risks), the lack of tests created a real risk of erroneous results because Connecticut law gives the mother’s accusation special weight, and scientific blood tests often can conclusively exclude paternity. The State’s fiscal interest in avoiding test expenses existed, but federal reimbursement and other states’ practices showed the cost interest was not enough to outweigh the defendant’s rights. The Court concluded the denial of tests to an indigent defendant in these circumstances denied a meaningful opportunity to be heard and therefore violated due process.

Real world impact

The Court reversed the state appellate judgment and sent the case back for proceedings consistent with its opinion. Going forward, when the State is a party in paternity suits and an indigent defendant requests exclusionary blood testing, Connecticut courts must provide a way for those tests to be obtained at public expense or otherwise ensure access. The Court did not decide the Equal Protection question.