In the United States v. MacCollom case of 1975, the Supreme Court ruled on whether a defendant's right to due process was violated when he was denied free transcripts for his appeal because he could not afford them. The court held that there was no violation of due process rights in this situation. The majority opinion stated that while indigent defendants have a constitutional right to adequate appellate review, it does not automatically entitle them to free transcripts for their appeals if they cannot afford them. Instead, alternative methods such as providing an agreed statement of facts or a narrative account from the judge can be used instead of verbatim transcripts without violating due process rights.

In the dissenting opinion for United States v. MacCollom, Justice William J. Brennan Jr., joined by Justices Thurgood Marshall and Byron White, argued that the majority's decision was a departure from established precedent regarding federal habeas corpus procedures. They contended that denying prisoners access to transcripts of their trials if they could not afford them violated equal protection principles and hindered their ability to challenge their convictions effectively. The dissenters believed this ruling would disproportionately affect indigent defendants who lacked resources to secure these necessary documents for appeal or post-conviction relief proceedings, thereby creating an unjust system favoring those with financial means over those without.