What is the test for appointment of counsel in a criminal case?

"In determining the appropriate remedy to secure access, the trial court should consider the nature of the action, the potential effect on the prisoner's property, the necessity for the prisoner's presence, the prisoner's role in the action, the prisoner's literacy, intelligence and competence to represent himself or herself, the stage of the proceedings, the access of the prisoner to a law library and legal materials, the length of the sentence, the feasibility of transferring the prisoner to court and the cost and inconvenience to the prison and judicial systems. [Citations.]" (Wantuch v. Davis, supra, 32 Cal.App.4th at p. 793.)

Appointment of counsel is required only as the "last alternative" when no other form of relief will preserve the prisoner's right of access to the courts.¹³ (Yarbrough v. Superior Court, supra, 39 Cal.3d at p. 200; Payne v. Superior Court, supra, 17 Cal.3d at p. 924.) Bryner argues this is such a case.