M.L.B. v. S.L.J., 519 U.S. 102, 117 S. Ct. 555, 136 L. Ed. 2d 473 (1996)
M.L.B. v.
May a state condition an indigent parent's right to appeal from a decree terminating parental rights on prepayment of record-preparation fees and costs?
While the Constitution does not require states to provide appellate review, when a state elects to offer an appeal in cases implicating fundamental interests akin to those at stake in criminal proceedings, the Fourteenth Amendment's Due Process and Equal Protection Clauses prohibit the state from effectively denying access to that appeal based solely on indigency. In such cases, the state must provide a record of sufficient completeness to permit proper appellate review without charge to the indigent appellant.
No. The Fourteenth Amendment prohibits Mississippi from conditioning M.L.B.'s appeal from a decree permanently terminating her parental rights on prepayment of record-preparation fees. The state must provide an adequate record to an indigent appellant in such proceedings.
M.L.B. v. S.L.J. is a cornerstone case on constitutional access to the courts in civil matters involving fundamental rights. It refines the Griffin doctrine by extending transcript-access principles beyond criminal appeals to a tightly circumscribed class of civil appeals where the stakes are extraordinary. For law students, it illustrates the Court's "convergence" approach to Due Process and Equal Protection in access-to-justice cases; the calibration of constitutional protections by the nature of the interest at stake; and the requirement that states provide, at minimum, a record of sufficient completeness for indigent appellants in parental-rights terminations. The decision is frequently tested in exams and invoked in practice to argue for accommodations that enable meaningful appellate review when fundamental family interests are on the line.