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

M.L.B. (defendant) and S.L.J. (plaintiff) were the biological parents of two minor children. M.L.B. and S.L.J. divorced, and S.L.J. retained custody of the children with M.L.B.’s consent. S.L.J. subsequently remarried and brought an action in Mississippi Chancery Court to terminate M.L.B.’s parental rights so that the children could be adopted by S.L.J.’s new wife. M.L.B. opposed terminating her parental rights, but the chancery court ultimately entered a decree terminating M.L.B.’s parental rights and approving the children’s adoption. M.L.B. filed a timely appeal of the chancellor’s decision. Under Mississippi law, appellants in civil cases were required to prepay a fee to cover the costs of ordering and preparing relevant portions of the trial-court record and transmitting those materials to the appellate court. Mississippi claimed that the law was necessary to offset court costs, though very few civil appeals in Mississippi involved the termination of parental rights. The chancery court assessed a record-preparation fee of $2,352.36 for preparing the record relevant to M.L.B.’s appeal, but M.L.B. was unable to pay that amount. M.L.B. sought leave to appeal in forma pauperis (i.e., as an indigent person), but the Mississippi Supreme Court denied M.L.B.’s application and dismissed M.L.B.’s appeal. The United States Supreme Court granted certiorari.