Jafar v. Webb, 303 P.3d 1042

Jafar sought a parenting plan and filed a GR 34 fee waiver based on indigence.
Indigence alleged due to reliance on TANF and food stamps; monthly income $385.
Trial court found indigent but granted partial waiver: waived $200 filing fee, but taxed $20 facilitator surcharge and $30 judicial stabilization surcharge; required $50 within 90 days.
Formally, the fee waiver asked for “all” fees and surcharges; the court crossed out “all” and ordered partial payment.
This interlocutory action is reviewable on appeal; court remanded to waive all filing fees and surcharges.
GR 34 interprets indigence as requiring full waiver of fees to ensure access to justice.
The decision vacates the trial court’s order and directs full waiver of all fees and surcharges for indigent litigants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does GR 34 require full waiver of fees for indigent litigants?	Jafar: rule mandates full waiver.	WACO: court may partially waive.	Full waiver required; partial waiver improper.
May a trial court grant partial waivers under GR 34 after indigency is found?	Jafar: no partial waivers allowed.	WACO: discretionary to waive all, some, or none.	Partial waivers not permitted; must waive all.
Is Jafar's challenge ripe for review?	Indigence and fee payment obligation affect access now.	Not addressed specifically.	Claim held ripe; legal question can be resolved on record.

Griffin v. Illinois, 351 U.S. 12 (1956) (due process and equal protection require access to courts for indigents in civil matters)
Boddie v. Connecticut, 401 U.S. 371 (1971) (due process and equal protection in civil family-law contexts; access to courts)
M.L.B. v. S.L.J., 519 U.S. 102 (1996) (appellate review limitations in civil cases; selective applicability to family rights)
O’Connor v. Matzdorff, 76 Wn.2d 589 (1969) (state duty to waive fees to protect access to courts; indigence context)
Iverson v. Marine Bancorporation, 83 Wn.2d 163 (1973) (state's duty to open courts to indigents; fees for appeals)