Yarbrough v. Superior Court of Napa County

In 1976 we decided in Payne v. Superior Court, 17 Cal. 3d 908 [132 Cal. Rptr. 405, 553 P.2d 565], that as a matter of due process and equal protection under both the federal and California Constitutions an indigent prisoner who is a defendant in "a bona fide legal action threatening his interests" is entitled to access to the courts to be heard in his defense. We left to the trial courts discretion how access is to be achieved in particular cases, recognizing that, at times, appointment of counsel may be the only alternative. We made it clear, however, that the trial courts authority to appoint counsel is independent of its power to order compensation.