Anthony Kane, Warden v. Joe Garcia Espitia (546 U.S. 9)
U.S. Supreme Court · decided October 31, 2005 · Supreme Court Database (Spaeth)
- Citation
- 546 U.S. 9 · 126 S. Ct. 407
- Decided
- October 31, 2005
- Term
- October Term 2005
- Vote
- 9–0
- Issue area
- Civil Rights
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Per Curiam. Respondent Garcia Espitia, a criminal defendant who chose to proceed pro se, was convicted in California state court of carjacking and other offenses. He had received no law library access while in jail before trial — despite his repeated requests and court orders to the contrary — and only about four hours of access, during trial, just before closing arguments. (Of course, he had declined, as was his right, to be represented by a lawyer with unlimited access to legal materials.) The California courts rejected his argument that his restricted library access violated his Sixth Amendment rights. Once his sentence became final, he petitioned in Federal District Court for a writ of habeas corpus under 28 U. S. C. § 2254. The District Court denied relief, but the Court of Appeals for the Ninth Circuit reversed, holding that “the lack of any pretrial access to lawbooks violated Espitia’s constitutional right to represent himself as established by the Supreme Court in Faretta [v. California, 422 U. S. 806 (1975)].” Garcia Espitia v. Ortiz, 113 Fed. Appx. 802, 804 (2004). The warden’s petition for certiorari and respondent’s motion for leave to proceed in forma pauperis are granted, the judgment below is reversed, and the case is remanded. A necessary condition for federal habeas relief here is that the state court’s decision be “contrary to, or involv[e] an unreasonable…
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