Michael Bush sought federal habeas relief after Florida courts rejected his postconviction claims, including a claim that roughly eighty percent of his trial transcript was unavailable for his state postconviction proceeding. He argued that the incomplete record violated due process and denied him access to the courts because he could not use the transcript to support ineffective-assistance claims. The Eleventh Circuit affirmed the dismissal of his petition. It distinguished the constitutional requirement for a record adequate to permit meaningful direct review of a conviction from the evidentiary role a transcript plays in a later postconviction proceeding. Bush had received an evidentiary hearing, was represented by counsel, testified about his recollection, examined witnesses, and had other portions of the record available. The court held that no clearly established Supreme Court precedent gave him a substantive due-process right to a complete transcript for that postconviction purpose, and that the missing material did not establish a constitutional violation under the applicable habeas standard.