fees in a narrow category of cases where the litigant has a “fundamental interest at stake.” M.L.B. v. S.L.J., 519 U.S. 102, 117 S.Ct. 555, 562, 136 L.Ed.2d 473 (1996). The Supreme Court has specifically required the waiver of filing fees for indigent persons who are challenging termination of their parental rights, id., or seeking a divorce, see Boddie v. Connecticut, 401 U.S. 371, 374, 91 S.Ct. 780, 28 L.Ed.2d 113 (1971). Conversely, the Supreme Court has held that discharge of debts in bankruptcy does not effect a fundamental interest and therefore waiver of filing fees is not constitutionally required. United States v. Kras, 409 U.S. 434, 444-45, 93 S.Ct. 631, 34 L.Ed.2d 626 (1973); see also Ortwein v. Schwab, 410 U.S. 656, 659, 93 S.Ct. 1172, 35 L.Ed.2d 572 (1973) (per curiam) (<HOLDING>). In this case, Rodriguez’s claim does not
holding that waiver of filing fees is not required where indigent person is challenging reduction of welfare benefits holding waiver did not preclude rule 32d motion challenging validity of waiver due to ineffective assistance of counsel holding that we do not consider the waiver issue where the government has not contended that these actions of defendant bespeaking waiver preclude defendant from challenging the relevant district court rulings holding that the word waiver is not required to waive a right even when a statute requires clear and unmistakable evidence of waiver holding that a delay in challenging personal jurisdiction may result in waiver