Kane v. Garcia Espitia

PETITIONER: Anthony Kane, Warden
RESPONDENT: Joe Garcia Espitia
LOCATION: United States Court of Appeals for the Ninth Circuit

DOCKET NO.: 04-1538
DECIDED BY: Roberts Court (2005-2006)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 546 US 9 (2005)
DECIDED: Oct 31, 2005
GRANTED: Oct 31, 2005

Facts of the case

Joe Garcia Espitia chose to represent himself in his trial on charges of carjacking and was convicted. Garcia Espitia was repeatedly denied law library access to prepare for trial, but he received four hours of access during trial just before closing arguments. He sought federal habeas relief, but the district court denied his petition. The U.S. Court of Appeals for the Ninth Circuit reversed and held that the lack of pretrial access to law books violated Garcia Espitia’s Sixth Amendment right to represent himself as established in Faretta v. California.

Question

Is denial of access to a law library a violation of the Sixth Amendment right to self-representation?