The article looks at the ramifications of the due process approach as it pertains to the alleged right to an effective psychiatrist. The author concludes that the current approach to due process would only allow a right to effective psychiatric assistance if the holding in Ake itself is broad enough to establish the right. He considers the circuit court arguments for and against the right under Ake, and completes the inquiry, concluding that only a limited right exists. The article concludes by offering a perspective for a result that some may find counterintuitive. Footnotes