Mlb v. Slj
Headline: Court bars states from denying appeals in parental-rights termination cases due to inability to pay record fees, protecting indigent parents’ access to appellate review when their parental relationship is permanently at stake.
Holding: In a civil appeal, a State may not deny an indigent parent's right to appellate review of a parental-rights termination by requiring advance payment for record preparation fees.
- Prevents states from blocking parental-rights appeals by demanding advance record fees.
- Requires a sufficient trial record so poor parents can challenge termination evidence.
- Pushes states to create funding or procedures to furnish records for indigent appellants.
Summary
Background
M. L. B. is the biological mother of two children whose parental rights were terminated by a Mississippi chancery court after a hearing brought by the children's father and his new wife seeking adoption. The trial judge's decree recited the statutory grounds and concluded there was clear and convincing evidence, but it gave no description of the evidence. When the mother filed a timely appeal, Mississippi required advance payment—more than $2,300—for preparing the trial record and transcript. Because she was indigent, she could not pay. The Mississippi Supreme Court denied her request to proceed in forma pauperis on appeal, and her appeal could not proceed for lack of the record.
Reasoning
The Justices reviewed prior cases that bar a State from conditioning access to appellate review on ability to pay for transcripts when serious, possibly permanent, interests are at stake. The Court found parental-rights termination is a uniquely severe and irreversible state action that threatens a fundamental family interest. Applying that precedent, the Court concluded Mississippi could not withhold a transcript and record completeness from an indigent parent seeking review of the sufficiency of the evidence.
Real world impact
The ruling reverses the Mississippi court's judgment and requires the State to provide a sufficient record so an indigent parent can pursue an appeal of a termination order. It does not decide the underlying fitness issues. The decision preserves appellate review for poor parents in termination cases, though procedures and funding mechanisms will be for state courts and legislatures to implement.
Dissents or concurrances
Justice Kennedy agreed with the result based on due process; other Justices warned this rule may extend beyond parental cases and urged caution.
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