In Pennsylvania v. Finley, 481 U.S. 551 (1987), the United States Supreme Court held that the stringent requirements of Anders did not apply to appointed counsel seeking to withdraw from representation of clients attempting to collaterally attack their convictions through Pennsylvania's Post-Conviction Hearing Act (PCHA). The Supreme Court stated that the rationale of Anders rested on the Court's decision in Douglas v. California, 372 U.S. 353, 83 S. Ct. 814, 9 L. Ed. 2d 811 (1963), in which it held that "denial of counsel to indigents on first appeal as of right amounted to unconstitutional discrimination against the poor." Finley, 481 U.S. at 554. The Court noted that there is no constitutional right to counsel in discretionary appeals from convictions or collateral attacks upon convictions. Id. at 555. The Supreme Court concluded that merely because the Commonwealth had chosen to provide assistance of counsel to individuals attacking their convictions through the PCHA, the United States Constitution did not dictate "the exact form such assistance must assume." Id. at 559. The United States Supreme Court ruled that the federal constitutional "right to appointed counsel extends to the first appeal of right, and no further." (Finley, supra, 481 U.S. at p. 555.) Accordingly, the Court reasoned, "access to a lawyer is the result of the State's decision, not the command of the United States Constitution." (Id. at p. 556.) The Court held that the federal constitutional right to counsel does not extend to post-conviction challenges: "We have never held that prisoners have a constitutional right to counsel when mounting collateral attacks upon their convictions, and we decline to so hold today. Our cases establish that the right to appointed counsel extends to the first appeal of right, and no further. Thus, we have rejected suggestions that we establish a right to counsel on discretionary appeals. We think that since a defendant has no federal constitutional right to counsel when pursuing a discretionary appeal on direct review of his conviction, a fortiori, he has no such right when attacking a conviction that has long since become final upon exhaustion of the appellate process."