Supreme Court of the United States
Little v. Streater
June 1, 1981452 U.S. 1
Summary
The Court held that applying Connecticut's cost-shifting statute to deny an indigent defendant access to court-ordered blood grouping tests in a publicly supported paternity action violated due process. The State's substantial involvement, the defendant's evidentiary disadvantage, the importance of accurate paternity determinations, and the tests' significant exculpatory value outweighed the State's financial interest. The Court reversed and remanded without reaching the equal protection claim.
Holding
- Due process access to blood grouping tests in an indigent defendant's paternity action. When the State substantially participates in a paternity proceeding, imposes an evidentiary burden on the putative father, and the defendant is indigent, due process requires access to blood grouping tests with substantial potential to exonerate him; applying the statute to deny those tests solely because of his inability to pay violated the Fourteenth Amendment.
Docket 79-6779
Cited authorities
- 42 U.S.C. § 655
- Conn. Gen. Stat. § 52-184
- 13 J. Fam. L. 713
- 42 U.S.C. § 655
- 42 U.S.C. § 1302
- 45 C.F.R. § 304.20
- Kan. Stat. Ann. § 23-132
- N.H. Rev. Stat. Ann. §522:3