State v. Wang, 312 Conn. 222

Indigent Wang waives counsel and proceeds pro se with standby counsel to assist with defense; he seeks publicly funded experts and an investigator.
The matter is framed as four reserved questions under § 52-235 and Practice Book § 73-1, concerning funding for ancillary defense tools for self-represented indigents.
The trial court reserved four questions; the Supreme Court has jurisdiction to answer them under § 52-235 and § 73-1, and the questions are ripe.
Court adopts affirmative answer to Q1, negative to Q2, affirmative to Q3, and declines to answer Q4 due to ruling on Q3.
Statutory scheme vests funding authority in the Commission on Public Defender Services; the Commission funds reasonably necessary ancillary costs upon approved requests; standby counsel can obtain funding for a self-represented defendant.
Court remands for compliance with its decision and confirms that funding for ancillary defense costs for self-represented indigents may come from the Commission rather than the Judicial Branch.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether indigent self-represented defendants are entitled to public funds for expert/investigative services	Wang argues due process requires access to these tools	State agrees on fairness but defers to administrative mechanisms	Yes
Whether the trial court retains discretion to fund such services based on a threshold necessity	Discretion should lie with court to ensure fair defense	Administrative funding should be controlled by the Commission	No
Whether the Commission or Judicial Branch may fund reasonably necessary ancillary defense costs	Commission has statutory authority to fund these costs	Judicial Branch may fund or there is policy limiting Commission funds	Commission may fund

Ake v. Oklahoma, 470 U.S. 68 (U.S. Supreme Court, 1985) (due process right to access to necessary defense tools)
Gideon v. Wainwright, 372 U.S. 335 (U.S. Supreme Court, 1963) (right to counsel for indigent defendants; basis for tools of defense)
Douglas v. California, 372 U.S. 353 (U.S. Supreme Court, 1963) (assistance of counsel on first direct appeal as of right)
Faretta v. California, 422 U.S. 806 (U.S. Supreme Court, 1975) (standards for self-representation)
Ross v. Moffitt, 417 U.S. 600 (U.S. Supreme Court, 1974) (limits of right to counsel to indigents)
Ake v. Oklahoma (duplicate entry for emphasis), 470 U.S. 68 (U.S. Supreme Court, 1985) (see above)
State v. Hudson, 154 Conn. 631 (Conn. 1967) (purpose of public defender system to protect indigent rights)
Gipson v. Commissioner of Correction, 257 Conn. 632 (Conn. 2001) (separation between public defender system and judiciary)
State v. Clemons, 168 Conn. 395 (Conn. 1975) (indigent access to expert testimony when necessary)
State v. Fernandez, 254 Conn. 637 (Conn. 2000) (standby counsel as an avenue to access legal information)
State v. Shashaty, 251 Conn. 768 (Conn. 1999) (standby counsel access to legal materials)
In re Cannady, 126 N.J. 486 (N.J. 1991) (public defender authority to fund outside counsel expenses)
State v. Brown, 139 N.M. 466 (N.M. 2006) (simultaneous rights to counsel and tools of defense)
McKaskle v. Wiggins, 465 U.S. 168 (U.S. Supreme Court, 1984) (standby counsel role in aiding pro se defendants)