The analysis focused on the law governing the appointment of counsel in State post-conviction proceedings in capital cases, the compensation of court-appointed attorneys for their time and expenses, and the actual systems that States have established to provide representation in these cases. National statistics indicate that increasing numbers of capital cases will soon enter the post-conviction process and will place large burdens on the judicial system. States vary widely in the systems providing counsel at the State post-conviction level. Some require the local public defender involved in the trial to remain as counsel. Others require the appointed private attorney or a newly appointed private counsel to provide representation. Additional systems include the use of contract attorneys, the appellate defender unit of the statewide public defender program, an independent State appellate program, or volunteer counsel. Statutory provisions for fees vary widely also. Nevertheless, attorneys spend large amounts of time on post-conviction matters. In addition, many attorneys have donated large amounts of time and energy to assure that no person under sentence of death is without the benefit of counsel at any stage of review. Footnotes and discussion of the potential impact of the pending decision in Murray v. Giarratano.