By Laurie Asseo and Greg Stohr
Oct. 31 (Bloomberg) -- The U.S. Supreme Court ruled that a California inmate convicted of carjacking isn't entitled to a new trial because he was given almost no access to a jail law library while representing himself in court.
The justices, in an unsigned opinion, reversed a lower court ruling that granted Joe Garcia Espitia a new trial. The justices said that because there is no established right of access to a prison law library for defendants representing themselves, Espitia couldn't win reversal of his state-court conviction in federal court.
Espitia, who was in jail while awaiting trial, was given no law library access before his trial began and about four hours of access just before closing arguments.
The San Francisco-based 9th U.S. Circuit Court of Appeals had ruled that he must be given a new trial, saying the lack of law library access violated his constitutional right to represent himself, as established by the Supreme Court in 1975. The 9th Circuit ruling conflicted with decisions by five other federal appeals courts around the country.
At issue in the state's appeal to the high court was the legal standard for federal court review of state court convictions. California Attorney General Bill Lockyer said the 9th Circuit shouldn't have overturned the conviction in the absence of a Supreme Court decision that squarely entitles defendants to library access.
In ruling for the state, the Supreme Court said its 1975 decision ``says nothing about any specific legal aid that the state owes'' defendants who represent themselves in court.
Lawyers Dismissed
Espitia dismissed two lawyers in the months leading up to his trial. He requested access to a law library at least four times before trial, according to the 9th Circuit decision. He was sentenced to 38 years to life under California's ``three strikes and you're out'' law, which is aimed at repeat offenders.
His lawyer, W.C. Melcher, said in court papers that jail authorities defied repeated orders from the trial judge handling the case to provide law library access.
``Espitia was deprived of any pretrial access to legal research materials and, accordingly, of any opportunity to make a meaningful defense,'' Melcher argued.
The case is Kane v. Espitia, 04-1538.
To contact the reporter on this story: Laurie Asseo in Washington at lasseo1@bloomberg.net.
Last Updated: October 31, 2005 11:40 EST
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