the courts. Although, before now, we have not addressed directly this precise question, we have indicated in dicta that “the provision of counsel can be a means of accessing the courts” that satisfies a state’s constitutional obligation to provide pretrial detainees with access to the courts. Benjamin v. Fraser, 264 F.3d 175, 186 (2d Cir.2001) (considering whether prison restrictions on detainees’ contact with their attorneys violated the detainees’ constitutional rights to counsel and of access to the courts). Moreover, several of our sister circuits already have interpreted appointment of counsel as a valid means of providing pretrial detainees and other prisoners with constitutionally mandated access to the courts. See, e.g., United States v. Smith, 907 F.2d 42, 45 (6th Cir. 1990) (<HOLDING>); Peterkin v. Jeffes, 855 F.2d 1021, 1042 (3d
recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel holding that the state does not have to provide access to a law library to defendants in criminal trials who wish to represent themselves and waive their right to counsel holding that the total denial of all access to the law library for seven months violated the plaintiffs constitutional right of access to the courts holding that prisoner did not have right to access law library because he had courtappointed counsel holding that defendants have a right to counsel in criminal proceedings