United States v. Hawthorne, 6:23-cr-00090

Gabriel Hawthorne was convicted by a jury of drug trafficking and sentenced to concurrent prison terms.
His appeal was dismissed for want of prosecution; he later sought appointment of counsel on grounds of indigence, which was granted.
Hawthorne moved to unseal and obtain copies of the jury selection (voir dire) transcripts, claiming a need for them to file a 28 U.S.C. § 2255 motion for ineffective assistance of counsel claims.
The Court partially unsealed the transcripts but required specific reasons for further unsealing, which Hawthorne did not provide.
Hawthorne, proceeding pro se, filed a motion to compel the Clerk of Court to provide him with free copies of the voir dire transcripts based solely on his indigence.
The Court addressed whether Hawthorne was entitled to free transcripts for post-conviction collateral proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to free voir dire transcripts for § 2255 motion	Hawthorne: Entitled to free transcripts due to indigence and need for collateral attack	U.S.: Law requires more than indigence; specific, non-frivolous grounds must be shown	Denied: Indigence alone insufficient; must specify necessity for the transcripts

U.S. v. Ramos-Barrera, [citation="466 F. App'x 334"] (5th Cir. 2012) (court may provide free transcripts to indigent defendants if needed for a non-frivolous § 2255 claim; mere indigence does not suffice)