M.L.B. v. S.L.J.

M.L.B. v. S.L.J.
Supreme Court of the United States
Argued October 7, 1996 Decided December 16, 1996
Full case name	M. L. B., petitioner v. S. L. J., individually and as next friend of the minor children, S. L. J. and M. L. J., et ux.
Citations	519 U.S. 102 (more) 117 S. Ct. 555; 136 L. Ed. 2d 473; 1996 U.S. LEXIS 7647; 65 U.S.L.W. 4035; 96 Cal. Daily Op. Service 9032; 96 Daily Journal DAR 14946; 10 Fla. L. Weekly Fed. S 221
Case history
Prior	Griffin v. Illinois, 351 U.S. 12; Mayer v. Chicago, 404 U.S. 189
Holding
Just as a state may not block an indigent petty offender's access to an appeal afforded to others, Mississippi may not deny M.L.B., because of her poverty, appellate review of the sufficiency of the evidence on which the trial court based its parental termination decree.
Court membership
Chief Justice William Rehnquist Associate Justices John P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy David Souter · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer
Case opinions
Majority	Ginsburg, joined by Stevens, O'Connor, Souter, Breyer
Concurrence	Kennedy
Dissent	Rehnquist
Dissent	Thomas, joined by Scalia; Rehnquist (except part II)
Laws applied
U.S. Const. amend. XIV

M.L.B. v. S.L.J., 519 U.S. 102 (1996), was a Supreme Court of the United States case regarding a controversy over the Fourteenth Amendment. The petitioner, M.L.B., argued that the Mississippi Chancery Courts could not terminate her parental rights on the basis that she was unable to pay the court fees. M.L.B. had been sued by S.L.J. to terminate M.L.B.'s parental rights and gain the ability to adopt the children. The judge declared in favor of S.L.J. under the premise that the decree was fair, as it was based on the fulfilling of the burden of proof by the father and his second wife with "clear and convincing evidence."^[1]

Despite the statement, the Chancery Court never elaborated on the evidence or clearly explained why M.L.B.'s parental rights had been dismissed. When M.L.B. went to appeal, she was unable to pay for the record preparation fees of $2,352.36 and so was denied. She then went to appeal under in forma pauperis but was again denied on the grounds that in forma pauperis is not demanded in civil cases, only criminal cases.

The case was then brought to the Supreme Court, where M.L.B. held that an inability to pay court fees should not be decisive of something as precious as parental rights. She used the guidelines set out in the due process and equal protection clauses of the Fourteenth Amendment to fight her case.

The Supreme Court decided in the petitioner's favor and stated that in matters regarding parental rights, a court may not stop a party from appealing the case based on financial means.

Because this ruling extended in forma pauperis to civil cases, there was a question of how liberally it could be applied. It was then clarified that in forma pauperis may be applied to civil cases only if state controls or intrusions on family relationships are involved.^[2] The Supreme Court decided that the family unit is considered so fundamental that its liberty interests should be protected by the Fourteenth Amendment. The protection of appellate rights was considered to be just as important as that of criminal rights.