In Murray v. Giarratano the plurality argued that equal protection and due process rights to state-appointed attorneys for mandatory appeals are sufficient and that the Constitution does not mandate state-appointed attorneys for state postconviction appeals. The dissent focused on the Fourteenth Amendment and maintained that the procedures at trial and direct appeal fail to meet the standards of accuracy necessary in death penalty cases. Thus, it correctly noted that the Murray decision failed to offer death row inmates a constitutional right to meaningful access to the courts. It should have recognized the continuity involved in the doctrines of the right to assistance of counsel and meaningful access to the courts. Taking an individual's life is too important and irreversible an action to allow without the procedural safeguard of government-appointed attorneys during a crucial part of the adjudication process. 146 footnotes.