138). However, state-appointed attorneys are often extremely overworked, underpaid, and lack the trial experience required for death penalty cases. In extreme cases, there have been cases where appointed lawyers slept during parts of the trial, or arrived at court under the influence of alcohol (Ibid, 1988; Death Penalty Info, n.d.; Joy ​​and McMunigal, 2012); this violates the accused's constitutional right to effective counsel, as well as the provision of the ICCPR granting the accused the right to a fair trial (Ibid, 1988). In support of this, in 2001, US Supreme Court Justice Ruth Bader Ginsburg stated: "People who are well represented at trial don't get the death penalty […] I haven't seen a death case yet among the dozens who have appeared before the Supreme Court." Court on pre-execution stay applications where the defendant was well represented at trial” (Death Penalty Info,