In Kane v. Espitia, the U.S. Supreme Court ruled that a California inmate was not entitled to a new trial due to lack of access to a jail law library despite his repeated requests and court orders to the contrary.
The court did note that “Of course, he had declined, as was his right, to be represented by a lawyer with unlimited access to legal materials.”
See the article in Bloomberg.com for more.
Source: Cincinnati Law Library Blog and Burning Ears Blawg