be imposed if the defendant did not have counsel at trial. As stated in Brewer v. Williams, , the right to counsel "[means] at least that a person is entitled to the help of a lawyer at or after the time that judicial proceedings have been initiated against him, whether by formal charge, preliminary hearing, indictment, information, or arraignment." Brewer goes on to conclude that once adversary proceedings have begun against a defendant, he has a right to legal assistance when the government interrogates him and that when a defendant is arrested, "arraigned on [an arrest] warrant before a judge", and "committed by the court to confinement", "[t]here can be no doubt that judicial proceedings ha[ve] been initiated." Self-representation A criminal defendant may represent himself, unless a court deems the defendant to be incompetent to waive the right to counsel. In Faretta v. California, , the Supreme Court recognized a defendant's right to pro se representation. However, under Godinez v. Moran, , a court that believes the defendant is less than fully competent to represent himself can require that defendant to be assisted by counsel. In Martinez v. Court of Appeal of California, , the Supreme Court ruled the right to pro se representation did not apply to appellate courts. In Indiana v. Edwards, 554 U.S. 164 (2008), the Court ruled that a criminal defendant could be simultaneously competent to stand trial, but not competent to represent himself. In Bounds v. Smith, , the Supreme Court held that the constitutional right of "meaningful access to the courts" can be satisfied by counsel or access to legal materials. Bounds has been interpreted by several United States courts of appeals to mean a pro se defendant does not have a constitutional right to access a prison law library to research his defense when access to the courts has been provided through appointed counsel. See also Trial in absentia United States constitutional criminal procedure References External links Kilman, Johnny and George Costello (Eds.). (2000). The Constitution of the United States of America: Analysis and Interpretation. CRS Annotated Constitution: Sixth Amendment Chin, Gabriel and Scott Wells. (1998). "Can a Reasonable Doubt have an Unreasonable Price? Limitations on Attorneys Fees in Criminal Cases", 41 Boston College Law Review 1. 06 1791 in American law 1791 in American politics United States criminal constitutional law United States Sixth Amendment case law