Is a defendant's claim that he has been denied access to the library of the Federal Penitentiary Library necessary to prepare his defense?

A claim similar to the one at hand was presented in United States v. Chatman, 584 F.2d 1358 (4th Cir. 1973). That case involved an inmate who was convicted of charges arising out of a threatening letter the inmate had sent to a judge. The inmate indicated his desire to represent himself in pretrial proceedings, but claimed at trial that he could not proceed because he had not been permitted access to the penitentiary library to prepare his defense. Apparently, the defendant had been denied access to the available library because he was in segregated confinement. At trial, the defendant's motions for a continuance and an order permitting library access were denied.

In affirming the defendant's convictions, the Chatman court rejected the argument that Bounds v. Smith required library access, saying: