Constitutional Law - An Indigent\u27s Right to a Blood Test in a Paternity Suit

Modern courts frequently allow the use of blood grouping tests in paternity cases. There is now . . . practically universal and unanimous judicial willingness to give decisive and controlling evidentiary weight to a blood test exclusion of paternity. A 1976 report developed jointly by the American Bar Association and the American Medical Association confirmed the ability of blood grouping tests to exonerate innocent putative fathers. Many states have developed statutes relating to the use of blood grouping tests in paternity cases. The State of Connecticut has such a statute which provides that a court, on motion of any party, may order the parties to submit to blood grouping tests. The statute further provides that the cost of making such tests shall be chargeable against the party making the motion. The United States Supreme Court considered the constitutionality of this Connecticut provision in Little v. Streater. The Court held that the Connecticut statute, denying a defendant blood grouping tests because of his lack of financial resources, violated the due process guarantee of the Fourteenth Amendment. In a unanimous decision, the Court concluded the statute, requiring the party requesting blood grouping tests to pay for such tests, was a denial of an indigent\u27s opportunity to be heard