What is the test for obtaining a transcript of a criminal trial for an indigent criminal defendant?

Griffin v. Illinois (1956) 351 U.S. 12, 17, 76 S.Ct. 585, 100 L.Ed. 891 [concluding that due process and equal protection guaranteed an indigent criminal defendant a free transcript of trial proceedings in order to provide that defendant with access to the court of appeal, where he would receive an adequate and effective review of his criminal conviction].)¹ In my view, the issue of access to the courts and judicial system was not an issue in Dueas , nor is it an issue in the instant case.