In Britt v. North Carolina (1971) 404 U.S. 226, the court ruled that the defendant's need for the transcript was presumed, and the prosecution must bear the burden of rebuttal. (Id. at p. 227.) Two factors were identified as relevant to the determination of need: (1) the value of the transcript to the defendant in connection with the appeal, and (2) the availability of alternative means to fulfill the same function as the transcript. (Ibid.) As pointed out in Britt, Griffin and its progeny establish that the equal protection principle requires that states "provide indigent prisoners with the basic tools of an adequate defense or appeal, when those tools are available for a price to other prisoners. While the outer limits of that principle are not clear, there can be no doubt that the State must provide an indigent defendant with a transcript of prior proceedings when that transcript is needed for an effective defense on appeal." (Britt, supra, at p. 227)