Little v. Streater, 452 U.S. 1 (U.S. 1981)
Little v. Streater is a landmark due process decision at the intersection of constitutional procedure and family law.
Does the Due Process Clause of the Fourteenth Amendment require a state, when it initiates a paternity action against an indigent putative father, to provide blood-grouping tests at state expense upon the defendant's request?
Applying the Mathews v. Eldridge balancing test, due process requires the state to provide an indigent litigant with access to essential exculpatory evidence when: (1) the private interest affected is substantial; (2) the risk of erroneous deprivation without the requested procedure is significant and the procedure's probable value is high; and (3) the government's interest, including fiscal and administrative burdens, does not outweigh the need for the safeguard—especially where the government is itself the adversary in the proceeding.
Yes. Due process requires Connecticut to provide, at state expense, blood-grouping tests for an indigent defendant in a state-initiated paternity action when such tests are requested.
Little v. Streater is a cornerstone in procedural due process jurisprudence in civil cases involving significant private interests and an adversarial state. It affirms that indigent litigants are entitled to critical evidentiary tools when the state initiates proceedings and accuracy can be markedly improved at relatively low cost. The case presaged broader recognition of government-funded expert assistance in appropriate contexts and influenced statutory reforms ensuring routine availability of genetic testing in paternity matters. For law students, it illustrates how Mathews balancing can mandate affirmative state assistance, not merely notice and hearing, to ensure fundamental fairness.