Lisa Marie Michel v. New Hampshire

Whether due process permits a criminal defendant to bear the consequences of unresolved institutional facts necessary to determine compliance, materiality, prejudice, or meaningful review where the defendant cannot independently create or certify those facts and timely sought judicial procedures to establish them.

Whether due process permits preserved constitutional claims to be rejected for an. inadequate appellate record where the defendant identified the inadequacy before briefing and timely sought judicial establishment of material portions of the record she could not independently create.