What rights does a defendant have to access to Page 7 services?

A defendant's federal and state constitutional rights to self-representation include the right to all reasonably necessary means of presenting a defense. (People v. Blair (2005) 36 Cal.4th 686, 733.) "Thus, 'a defendant who is representing himself or herself may not be placed in the position of presenting a defense without access to a telephone, law library, runner, investigator, advisory counsel, or any other means of developing a defense.' [Citation.]" (Ibid.) The right to any of these means of presenting a defense is not absolute, however. For example, "'[institutional and security concerns of pretrial detention facilities may be considered in determining what means will be accorded to the defendant to prepare his or her defense. [Citations.]... In the final analysis, the Sixth Amendment requires only that a self-represented defendant's access to the resources necessary to present a defense be reasonable under all the circumstances. [Citation.]" (Ibid?) The question before us thus is whether defendant had "reasonable access to the ancillary services that were reasonably necessary for his defense." (Id. at p. 734.) To prevail on a claim that a self-represented defendant was denied access to ancillary

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services, the defendant must show not only error, but also resulting prejudice. (Id. at p. 736.)