No Court Access Violation to Deny Law Library Access to Pro Se Defendant
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The criminal defendant knowingly and voluntarily waived the right to counsel and represented himself. The fact that he did so contingent on having access to a law library and legal materials, which were not in fact available to him, did not matter. Providing legal counsel is a constitutionally acceptable alternative to providing a law library. The trial court offered him appointed counsel and then ordered counsel to stand by to provide the defendant expert legal assistance. It would have been better for the trial court to rule on the demand for law library access, but if it had denied the request, the defendant's rights would not have been violated. See: United States v. Taylor, 183 F.3d 1199 (10th Cir. 1999).