The right to counsel is a fundamental right, one the framers of our Constitution intended to apply to all American citizens. Virginia statutes and case law have protected the rights of incarcerated adults and it is now time to grant those same protections to the juveniles in their custody. Part II of this comment will review the requirement of a prisoner\u27s right to meaningful access to the courts from both an adult and juvenile\u27s perspective. An examination of jurisprudence from the Supreme Court of the United States, and Circuit Courts, reveals the history and importance of meaningful access and shows how different courts have applied the right. Part III will discuss how Virginia has interpreted meaningful access in the context...