Kane v. Garcia Espitia, 546 U.S. 9 (2005)

In Kane v. Garcia Espitia, Joe Garcia Espitia was convicted in a California state court of carjacking and other offenses. Espitia chose to represent himself in the trial and, despite multiple requests and court orders, he was denied access to a law library while in jail prior to his trial. He only received limited access to legal materials—approximately four hours—during the trial, just before closing arguments. Espitia argued that this lack of access violated his Sixth Amendment rights, which the California courts rejected. After his conviction and sentence became final, Espitia sought relief through a federal habeas corpus petition under 28 U.S.C. § 2254 in the Federal District Court, which denied his request. However, the Ninth Circuit Court of Appeals reversed this decision, concluding that the absence of pretrial access to law books infringed upon Espitia's constitutional right to represent himself, as established in the Supreme Court case Faretta v. California. The warden of the prison then petitioned the Supreme Court for a writ of certiorari, which was granted. The Supreme Court's opinion noted that the federal appellate courts had differing views on whether the right to self-representation implied a right to access a law library. However, the Court determined that Faretta did not establish a clear legal right to law library access for pro se defendants, and thus, the Ninth Circuit's ruling was deemed erroneous. The Supreme Court reversed the Ninth Circuit's judgment and remanded the case for further proceedings.

Whether the lack of access to a law library for a pro se defendant during pretrial and trial proceedings constitutes a violation of the defendant's Sixth Amendment rights, and if such a violation provides a basis for federal habeas relief under 28 U.S.C. § 2254.

The judgment below is reversed, and the case is remanded for further proceedings consistent with this opinion.