"In 1994 death penalty lawyer Stephen Bright published his seminal essay Counsel for the Poor: The Death Sentence Not for the Worst Crime but for the Worst Lawyer. His argument 'succinctly stated in the title' was that indigent defendants were disproportionately sentenced to death because their lawyers (who were often court-appointed) were under-resourced ill-prepared and failed at the most basic levels in their duty to represent their clients."