In Ross v. Moffitt, 417 U.S. 600, 608-12, 41 L. Ed. 2d 341, 94 S. Ct. 2437 (1974), the Court explicated the of limits the right to effective assistance of counsel. The Court said that there is no constitutional right to counsel on discretionary review after direct appeal. Moffitt, 417 U.S. at 615. This is because "the Fourteenth Amendment does not require absolute equality or precisely equal advantages." Id. at 612. The Supreme Court has held that states cannot adopt procedures that prevent a defendant from pursuing any appeal at all because of his indigence, or provide only "a 'meaningless ritual'for a poor defendant while others in better economic circumstances have a 'meaningful appeal.'" Ibid. But that is not the case in discretionary review after direct appeal.