BODDIE v. CONNECTICUT

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Case Basics
Docket No. 
27
Appellant 
Gladys Boddie et al.
Appellee 
Connecticut
Advocates
(reargued the cause for the appellants)
(reargued the cause for the appellee)
Tags
Term:
Facts of the Case 

Gladys Boddie was a married resident of Connecticut receiving welfare benefits. She filed for a divorce in New Haven County Superior Court. However, Boddie was not given a hearing because she had not paid the filing fee under Section 52-259 of the Connecticut General Statutes. Given her welfare status, she was unable to pay the fee. Her requests for fee waivers were also denied. Boddie and others who were denied divorces under Section 52-259 challenged the fee requirement in the United States District Court for the District of Connecticut. They alleged that the fee requirement violated the Due Process Clause of the Fourteenth Amendment. The District Court upheld the requirement. Boddie appealed to the Supreme Court.

Question 

Did Connecticut's fee requirement for divorce filings violate the Due Process Clause of the Fourteenth Amendment?

Conclusion 
Decision: 8 votes for Boddie, 1 vote(s) against
Legal provision: Due Process

Yes. In an 8-1 decision, the Court reversed the District Court and held the fee requirement unconstitutional. In a majority opinion authored by Justice John M. Harlan, the Court recognized the importance of "access to the courts" for Boddie, as state court was the only method of obtaining a divorce in Connecticut. While the Court acknowledged Connecticut's interest in conserving limited resources and preventing "frivolous litigation," this interest was not a "sufficient countervailing justification." Therefore, Connecticut's refusal to allow Boddie to proceed with her divorce was "a denial of due process" in violation of the Fourteenth Amendment. Justice William O. Douglas concurred in the result. Justice William J. Brennan, Jr. concurred in part.

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BODDIE v. CONNECTICUT. The Oyez Project at IIT Chicago-Kent College of Law. 14 September 2014. <http://www.oyez.org/cases/1960-1969/1969/1969_27>.
BODDIE v. CONNECTICUT, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1969/1969_27 (last visited September 14, 2014).
"BODDIE v. CONNECTICUT," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 14, 2014, http://www.oyez.org/cases/1960-1969/1969/1969_27.