Whether an indigent defendant can be compelled to accept the representation of appointed counsel and give up his Sixth Amendment right to represent himself, in order to obtain the tools necessary to present an adequate defense

QUESTION PRESENTED FOR REVIEW In Farretta v. California, 422 U.S. 806, 833-34 (1975), this Court recognized that the Sixth Amendment of the United States Constitution guarantees criminal defendants the right to self-representation at trial. This Court has also held that fundamental fairness requires that an indigent defendant be provided “access to the raw materials integral to the building of an effective defense.” Ake v. Oklahoma, 470 USS. 68, 77 (1985); see also Britt v. North Carolina, 404 U.S. 226, 227 (1971) (access to mistrial transcript or its equivalent when necessary for effective defense or appeal); Griffin v. Illinois, 351 U.S. 12, 19-20 (1956) (access to trial transcript or its equivalent when necessary to decision on merits). This Court, however, has never addressed the government’s obligation to provide access to defense tools necessary to present a competent defense to a self-represented indigent defendant. And state courts are split on this issue, where some state courts have held that Ake does not obligate the government to provide these tools when the defendant is self-represented, e.g. State v. Davis, 318 S.W. 3d 618, 636 (Mo. 2010), and others have found that denying access to these tools to pro se defendants violates their due process rights and their right to e.g. State v. Wang, 92 A. 3d 220, 231-232 (Conn. 2014). Thus the question presented is: Whether an indigent defendant can be compelled to accept the representation of appointed counsel and give up his Sixth Amendment right to represent himself, in order to obtain the tools necessary to present an adequate defense. i