fact that he was a repeat offender, having been convicted twice of burglary in Delaware. But these convictions had been obtained before the U.S. Supreme Court decision of Gideon v. Wainwright which guaranteed the right to counsel. He argued that since no defense attorney had been assigned to him in the Delaware cases, the two convictions were unconstitutional and thus the Virginia death sentence was unconstitutional as well. The courts rejected his contentions, resulting in decisions of the Virginia Supreme Court in Bloodgood v. Virginia and the United States Court of Appeals for the Fourth Circuit in Bloodgood v. Garraghty, 783 F.2d 470 (4th Cir. 1986). High rank possibly via manipulation Bloodgood organized chess games within Powhatan Correctional Center in Powhatan, Virginia, which were by necessity with fellow inmates. Many of these inmates were taught the game by Bloodgood, and thus began as unrated and inexperienced players. Bloodgood obtained USCF memberships for them. Some accused Bloodgood, with his intimate knowledge of the rating system, of rigging their ratings. The accusation was that he arranged for new prisoners to play rated games against other prisoners, who would deliberately lose, thus giving the new inmate an inflated USCF rating. Bloodgood, it is further alleged, then played rated games against the new highly rated prisoner, and each time he won, gained a few more rating points. This continued for several years, and by 1997 his rating rose to 2759, making the 59-year-old Bloodgood the second highest rated player in the nation, behind only Gata Kamsky. This is all a matter of considerable controversy even today. Bloodgood himself vehemently denied these accusations, and said that he played chess in the only competitions available to him, prison tournaments, and won almost every game because he was the strongest player in the prison system. As his rating rose, he wrote to the USCF to warn them that its system was prone to "closed pool" rating inflation. But nothing was done until Bloodgood's rating skyrocketed. By virtue of his high rating, Bloodgood would have qualified for entry into the U.S. Chess Championship, a prestigious invitation-only event intended for the best 16 players in the country. This caused an investigation by the USCF, which debated extensively what to do about the situation. In the end, Bloodgood wasn't invited to the event (which he could not have attended anyway), and the USCF changed its rating system rules to attempt