In the case of New York ex rel. Ray v. Martin, Warden (1945), the U.S Supreme Court was tasked with determining whether a state court's refusal to provide an indigent defendant with a free transcript for appeal violated his Fourteenth Amendment rights to due process and equal protection under law. The petitioner, William Ray, had been convicted in New York State courts on charges of first-degree robbery and assault but could not afford the cost of obtaining transcripts necessary for his appeal. He argued that this inability denied him access to appellate review solely based on his poverty status which he claimed was unconstitutional. The Supreme Court ruled 6-3 against Ray stating that there is no constitutional requirement mandating states must furnish defendants with trial records at public expense when they cannot afford it themselves. They held that while federal courts were required by statute to provide such services, no similar obligation existed for state courts under Constitution’s Due Process or Equal Protection Clauses.

In the dissenting opinion for New York ex rel. Ray v. Martin, Warden, Justice Frankfurter argued that the majority's decision to grant habeas corpus relief was inappropriate and overstepped federal authority into state matters. He contended that there were no constitutional issues at stake in this case as it primarily involved a question of state law interpretation which should be left to the discretion of state courts. Furthermore, he believed that granting such relief would undermine respect for finality in legal proceedings and disrupt judicial administration by encouraging prisoners to continually challenge their convictions on technical grounds rather than substantive ones. In his view, federal intervention should only occur when there is clear evidence of an egregious violation of constitutional rights or gross miscarriage of justice - neither of which were present here.