Little v. Streater
Annotate this Case
452 U.S. 1 (1981)
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U.S. Supreme Court
Little v. Streater, 452 U.S. 1 (1981)
Little v. Streater
Argued January 13, 1981
Decided June 1, 1981
452 U.S. 1
After appellee, while unmarried, gave birth to a female child, she identified appellant as the father to the Connecticut Department of Social Services, a requirement stemming from the child's receipt of public assistance. The Department then provided an attorney for appellee to bring a paternity suit against appellant in a Connecticut state court. Appellant moved the trial court to order blood grouping tests on appellee and her child pursuant to a Connecticut statute (§ 46b-168), which includes the provision that the cost of such tests shall be chargeable against the party requesting them. Asserting that he was indigent, appellant asked that the State be ordered to pay for the tests. The trial court granted the motion insofar as it sought the tests, but denied the request that they be furnished at the State's expense, with the result that no tests were performed. After a trial, the court found that appellant was the child's father, entered a damages judgment against him, and ordered him to pay child support directly to the State. The Appellate Session of the Connecticut Superior Court affirmed, holding, inter alia, that § 46b-168 does not violate the due process rights of an indigent defendant in paternity proceeding.
Held: In the circumstances of this case, application of § 46b-168 to deny appellant blood grouping tests because of his lack of financial resources violated the due process guarantee of the Fourteenth Amendment. Pp. 452 U. S. 5-17.
(a) Appellant's due process claim is premised on the unique quality
of blood grouping tests as a source of exculpatory evidence, the State's prominent role in the litigation, and the character of paternity suits under Connecticut law. In evaluating that claim, the following factors must be considered: the private interests at stake; the risk that the procedures used will lead to erroneous results, and the probable value, if any, of additional or substitute procedural safeguards; and the governmental interests affected. Mathews v. Eldridge, 424 U. S. 319, 424 U. S. 335. Pp. 452 U. S. 5-12.
(b) Assessment of these factors indicates that appellant did not receive the process he was constitutionally due. The private interests implicated are substantial. Given the usual absence of witnesses in a paternity suit, the self-interest coloring the litigants' testimony, Connecticut's onerous evidentiary rule that the reputed father's testimony alone is insufficient to overcome the mother's prima facie case, and the State's refusal to pay for blood grouping tests, the risk is not inconsiderable that an indigent defendant will be erroneously adjudged the father. Furthermore, because of its recognized capacity to definitively exclude a high percentage of falsely accused putative fathers, the availability of scientific blood test evidence clearly would be a valuable procedural safeguard in such cases. And the State's financial interest in avoiding the expenses of blood grouping tests is not significant enough to overcome the substantial private interests involved, particularly where federal funds are available to help defray such expenses and the State could advance such expenses and then tax them as costs to the parties. Thus, without aid in obtaining blood test evidence in a paternity case, an indigent defendant, who faces the State as an adversary when the child is a recipient of public assistance and who must overcome the evidentiary burden Connecticut imposes, lacks "a meaningful opportunity to be heard." Pp. 452 U. S. 13-16.
Reversed and remanded.
BURGER, C.J., delivered the opinion for a unanimous Court.