Does a denial of a transcript violate a defendant's right to prepare an adequate defense de novo?

MultiRegion, United States of America

The following excerpt is from U.S. v. Kirk, 844 F.2d 660 (9th Cir. 1988):

We review a claim that the denial of a transcript request violated a defendant's constitutional right to prepare an adequate defense de novo. See United States v. McConney, 728 F.2d 1195, 1202-04 (9th Cir.) (en banc), cert. denied, 469 U.S. 824, 105 S.Ct. 101, 83 L.Ed.2d 46 (1984). We will not reverse the conviction if the denial was harmless beyond a reasonable doubt. United States v. Rosales-Lopez, 617 F.2d 1349, 1355 (9th Cir.1980) aff'd, 451 U.S. 182, 101 S.Ct. 1629, 68 L.Ed.2d 22 (1981).

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