What is Ake's analysis of the need for "meaningful access to justice"?

Ake begins its analysis of the need for "meaningful access to justice" by speaking of the "basic tools of an adequate defense or appeal." Id. at 77, 105 S.Ct. at 1093, quoting Britt v. North Carolina, 404 U.S. 226, 227, 92 S.Ct. 431, 433, 30 L.Ed.2d 400 (1971). Ake then emphasizes the metaphor of useful implements by twice referring to such "tools." Id. at 77, 105 S.Ct. at 1093. The emphasis on tools is an emphasis on function. A non-functioning tool is useless; so is a non-functioning psychiatrist.