No Right To Attorney In Collateral Review

The U.S. Supreme Court has declined a chance to review its holding that there is no right to an attorney for a collateral review of a conviction, even in a death penalty case. This means that despite the fact that there is a constitutional right to habeas corpus, the right is all but useless to the large number of prisoners who have no attorney, because elaborate procedural rules in habeas corpus are beyond the abilities of most prisoners (who are mostly ill educated). It also means the ineffective assistance of counsel in habeas corpus cases is not a constitutional violation.