What is the difference between offering a defendant the services of counsel to conduct his defense and offering the counsel's assistance?

MultiRegion, United States of America

The following excerpt is from Milton v. Morris, 767 F.2d 1443 (9th Cir. 1985):

There is a distinction between offering a defendant the services of counsel to conduct his defense and offering the counsel's assistance to a defendant who wishes to conduct his own defense. A defendant has the sixth amendment right under Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975) to refuse the former and to elect to conduct his own defense. In doing so, he may be offered the assistance of counsel in a variety of ways--for pretrial preparation and during trial. This assistance of counsel to a confined defendant would provide an adequate access to the resources necessary for him to conduct his defense.

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