In the 1993 case of Orrin S. Reed v. Robert Farley, Superintendent, Indiana State Prison et al., the U.S Supreme Court addressed an appeal from a prisoner who claimed his constitutional rights were violated when he was denied access to law books and legal assistance while in solitary confinement. The court ruled that prisoners do not have an absolute right to a law library or legal assistance; rather they are entitled to "meaningful access" to the courts which can be provided in various ways such as through provision of state-paid lawyers or paralegals, private volunteer attorneys etc. In this case, it was found that Reed had been given meaningful access despite being denied physical access to a law library because he had been able to file several lawsuits during his time in prison.

In the dissenting opinion for Orrin S. Reed v. Robert Farley, Superintendent, Indiana State Prison et al., Justice Blackmun argued that the majority's decision to deny habeas corpus relief was incorrect due to a misinterpretation of precedent and an overly narrow view of what constitutes ineffective counsel. He contended that Reed's trial lawyer failed in his duty by not investigating or presenting available mitigating evidence during the sentencing phase of his client’s capital murder trial. This failure, according to Justice Blackmun, amounted to constitutionally deficient performance under Strickland v. Washington (1984). Furthermore, he believed there was reasonable probability that this deficiency altered the outcome of Reed's sentencing; thus satisfying both prongs required for establishing ineffective assistance of counsel claim under Strickland standard.