In Connecticut, when a mother received public assistance, state law required her to assign her child-support rights to the state and authorized the state to initiate a paternity action against the putative father to obtain support and reimbursement. The state, acting on behalf of the mother, brought a paternity suit against Little, who denied paternity and was indigent. Connecticut law allowed courts to order blood-grouping tests upon motion, but required the moving party to pay for them; there was no provision for public funding when the defendant was indigent. Little moved for blood tests and asked that they be conducted at state expense. The trial court denied state-funded testing because the statute placed costs on the requesting party, and Little could not afford to pay. The court adjudicated paternity largely on testimonial evidence and entered a support order. On appeal, the state courts rejected Little's due process challenge to the denial of state-funded testing. Little sought and obtained Supreme Court review.
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.
The Court employed the Mathews v. Eldridge framework. First, it emphasized the substantial private interests at stake: an erroneous paternity determination creates long-term financial obligations and carries social stigma, and it may have collateral legal consequences. Second, the risk of error without scientific testing in a credibility-driven paternity trial is substantial. Blood-grouping tests, while not conclusively proving paternity, have significant probative value because they can reliably exclude a high percentage of wrongly accused men and thus sharply reduce the risk of mistaken adjudications. The state's argument that such tests were merely corroborative did not diminish their value in preventing error. Third, the governmental interests did not outweigh the need for the safeguard. Connecticut's primary asserted interest was fiscal—avoiding the costs of testing. The Court found those costs modest relative to the importance of accurate determinations and the potential savings generated by preventing erroneous support orders. Moreover, the state was not a neutral arbiter; it was the real party in interest, pursuing reimbursement and support as a condition of the mother's receipt of public assistance. Where the state compels the litigation and stands adverse to an indigent defendant, due process requires a level procedural playing field on matters essential to accuracy. The Court also noted that providing tests furthers the state's legitimate interest in reliable paternity determinations and efficient child support enforcement. Accordingly, Connecticut's rule placing the cost of essential scientific testing on an indigent defendant violated fundamental fairness under the Fourteenth Amendment.
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.
Little v. Streater marks an important development in due process doctrine by requiring not only formal procedures but also meaningful access to critical evidence where the state prosecutes a civil action against an indigent. Recognizing the pivotal role of scientific testing in paternity determinations, the Court insisted on a fair opportunity to avoid a life-altering, erroneous judgment.