M. L. B. v. S. L. J., Individually and As Next Friend of the Minor Children, S. L. J. and M. L. J., et ux.
The Court ruled for a mother whose parental rights were terminated and who could not afford record preparation fees, holding that a court may not bar an appeal in parental rights cases because of a party's financial means.· AI-written
519 U.S. 102 · No. 95-853 · 1996 term · Rehnquist Court
Decided Dec 16, 1996 · argued Oct 7, 1996
Civil rights · Indigents: costs or filing fees
Struck down a state law
Majority opinion: Ruth Ginsburg
The voteMajorityDissent
6–36 in the majority, 3 in dissent
3 dissents (6–3)
Reversed and remanded. M. L. B. won.
What this ruling means
Reversed and remanded: the Supreme Court overturned the decision of the Mississippi Supreme Court and sent the case back to that court for further proceedings that follow the Supreme Court’s ruling.
M. L. B. was the petitioner, the side that asked the Supreme Court to review the case. “Won” means the Court gave that side the result it asked for.
From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.
Summary
The opening of the case’s Wikipedia article: what the case was about and what the Court held.
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."
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. 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.
Data notes
The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.
How the justices voted
Each justice who took part, placed by their Martin–Quinn ideology score for the 1996 term. Filled: the 6 in the majority. Hollow: the 3 in dissent. Colour is the party of the president who appointed them.
Majority(6)
Ruth GinsburgWrote the majority opinion
Anthony KennedyWrote a concurrence
John StevensJoined the majority
Stephen BreyerJoined the majority
David SouterJoined the majority
Sandra O'ConnorJoined the majority
Dissent(3)
William RehnquistWrote a dissent
Clarence ThomasWrote a dissent
Antonin ScaliaJoined a dissent
Data notes
Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.
Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.
The parties
Who brought the case to the Court, who answered it, and how it got there.
- Petitioner
- M. L. B.Mother
- Respondent
- S. L. J., Individually and As Next Friend of the Minor Children, S. L. J. and M. L. J., et ux.Child, children
- Reached the Court by
- Certiorari (the Court chose to hear it)
Data notes
The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.
The law at issue
The law the Court was asked to apply, and the kind of power it used to decide.
- Provision
- Fourteenth Amendment (equal protection)
- Kind of law
- Constitutional Amendment
- Decided by
- Judicial review (state level)
- Struck down
- A state law, as unconstitutional
Data notes
The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.
Timeline
What happened at the Court and how the case got there, newest first.
- Dec 16, 1996DecidedDecided · Decided 6–3: reversed and remanded. M. L. B. won.
- Oct 7, 1996ArguedArgued · Oral argument before the Court.
- Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari).
- Not datedCourt belowCourt below · Decided by the Mississippi Supreme Court: petition denied or appeal dismissed.
- Not datedBeganBegan · The case began in the Mississippi trial court.
Data notes
From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.
Other decisions on the same issue
14 other argued cases since 1946 on indigents: costs or filing fees, newest first.
- Lomax v. Ortiz-Marquez140 S. Ct. 1721Jun 8, 2020 · 140 S. Ct. 1721Civil rights9–0Unanimous band
- Bruce v. Samuels577 U.S. 1021Jan 12, 2016 · 577 U.S. 1021Civil rights9–0Unanimous band
- Coleman v. Tollefson575 U.S. 532May 18, 2015 · 575 U.S. 532Civil rights9–0Unanimous band
- George F. Denton, Director of Corrections of California, et al. v. Mike Hernandez504 U.S. 25May 4, 1992 · 504 U.S. 25Civil rights7–27–2 band
- Little v. Streater452 U.S. 1Jun 1, 1981 · 452 U.S. 1Civil rights9–0Unanimous band
- Fuller v. Oregon417 U.S. 40May 20, 1974 · 417 U.S. 40Civil rights7–27–2 band
- United States v. Kras409 U.S. 434Jan 10, 1973 · 409 U.S. 434Civil rights5–45–4 band
- James, Judicial Administrator, et al. v. Strange407 U.S. 128Jun 12, 1972 · 407 U.S. 128Civil rights9–0Unanimous band
- Huffman v. Boersen406 U.S. 337May 15, 1972 · 406 U.S. 337Civil rights9–0Unanimous band
- Schilb et al. v. Kuebel et al.404 U.S. 357Dec 20, 1971 · 404 U.S. 357Civil rights4–36–3 band
- Boddie et al. v. Connecticut et al.401 U.S. 371Mar 2, 1971 · 401 U.S. 371Civil rights8–18–1 band
- Smith v. Bennett, Warden365 U.S. 708Apr 17, 1961 · 365 U.S. 708Civil rights9–0Unanimous band
- Burns v. Ohio360 U.S. 252Jun 15, 1959 · 360 U.S. 252Civil rights6–27–2 band
- Adkins, Administratrix, v. E. I. DuPONT de Nemours & Co., Inc. United States, Intervenor335 U.S. 331Nov 22, 1948 · 335 U.S. 331Civil rights9–0Unanimous band
Data notes
Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.
Official record
Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.