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competent enough to defend himself at trial. Supreme Court holds that “…the Constitution permits States to insist upon representation by counsel for those competent enough to stand trial under Dusky but who still suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves.” The Sixth Amendment right to defend oneself at trial, which was announced in Faretta v. California , 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975), is not an absolute right; the court must ensure that “proceedings […] not only be fair, they must appear fair to all who observe them.” Allowing a mentally incompetent defendant to defend himself at trial can result in an unfair proceeding and possibly in humiliation of the defendant. “In our view, a right of self-representation at trial will not affirm the dignity of a defendant who lacks the mental capacity to conduct his defense without the assistance of counsel [citations omitted]. To the contrary […] the spectacle that could well result from his self-representation at trial is at least as likely to prove humiliating as ennobling.” Further, the nature of mental illnesses is such that the competence of a mentally ill defendant may vary over time. Applying a universal standard for both the competence to stand trial and the competence to defend oneself would be inappropriate because “… in certain instances an individual may well be able to work with counsel at trial, yet at the same time he may be unable to carry out the basic tasks needed to present his own defense without the help of counsel.” Announces no standard or test for determining competency to self-represent; rejects standard proposed by Indiana “that would ‘deny a criminal defendant the right to represent himself at trial where the defendant cannot communicate coherently with the court or a jury.’” Scalia, joined by Thomas, dissents, would hold that “a defendant who is competent to stand trial, and who is capable of knowing and voluntary waiver of assistance of counsel, has a constitutional right to conduct his own defense.” Pulliam v. State, 287 Ga.App. 717, 653 S.E.2d 65 (September 5, 2007). Cocaine trafficking and related convictions affirmed. Trial court didn’t violate defendant’s right to proceed pro se where it denied his motion to discharge trial counsel immediately before jury selection on inadequate grounds. “ To assert reversible error resulting from a trial court’s denial of his motion to proceed pro se, [a defendant] must demonstrate that his assertion of that right was ‘unequivocal’ and made ‘prior to the commencement of his trial.’ (Punctuation and citation omitted.) Hayes v. State, 203 Ga.App. 143, 144(2) (416 S.E.2d 347) (1992).” Stating a desire to discharge counsel does not constitute an unequivocal assertion of the right to proceed pro se . “We note that where a defendant dismisses his attorney immediately before trial, he is deemed to have waived his right to counsel, and may be forced to proceed pro se. See, e.g., Hobson v. State, 266 Ga. 638, 639(2) (469 S.E.2d 188) (1996); Jefferson v. State, 209 Ga.App. 859, 861 (434 S.E.2d 814) (1993).” Moore v. State, 280 Ga.App. 894, 635 S.E.2d 253 (August 2, 2006). Burglary and related convictions affirmed; no violation of defendant’s right to self-represent. Prior to trial, defendant wrote to the court, expressed dissatisfaction with counsel, and announced his desire to “go pro se.” In a separate letter, Moore requested a new attorney. “At the beginning of the trial, defense counsel represented to the court that Moore was no longer dissatisfied with his services. When the court informed Moore that counsel’s associate would also be assisting with his defense, Moore raised no objection. Under these circumstances, no unequivocal assertion of Moore’s right to represent himself was made.” Phillips v. State, 278 Ga.App. 439, 629 S.E.2d 130 (March 24, 2006). Aggravated assault and related convictions affirmed. “‘[A] layperson does not have the right to represent himself and also be represented by an attorney.’ Seagraves v. State, 259 Ga. 36, 39 (376 S.E.2d 670) (1989). Accordingly, Phillips had no right to personally make evidentiary objections or otherwise assume the role of co-counsel.” Accord, Vadde v. State , 296 Ga.App. 405, 674 S.E.2d 323 (January 26, 2009) (defendant couldn’t file his own appellate brief where also represented by counsel); Powers v. State , 314 Ga.App. 733, 725 S.E.2d 848 (March 12, 2012) (trial court properly denied defendant’s request at trial to act as his own co-counsel); Barrett v. State , 292 Ga. 160, 733 S.E.2d 304 (October 15, 2012). Clark v. State, 278 Ga.App. 412, 629 S.E.2d 103 (March 23, 2006). Kidnapping conviction affirmed. Physical precedent only. 1. Incarcerated pro se defendant failed to show error in allegedly obstructing his access to legal research materials. “[R]egarding the issue of access to legal material, the U.S. Supreme Court held that ‘an inmate cannot establish relevant actual injury simply by establishing that his prison’s law library or legal assistance program is subpar in some theoretical sense.... [M]eaningful access to the courts is the touchstone, and the inmate therefore must go one step further and demonstrate that the alleged shortcomings in the library or legal assistance program hindered his efforts to pursue a legal claim.’ (Citations and punctuation omitted.) Lewis v. Casey, 518 U.S. 343, 351 (116 S.Ct. 2174; 135 L.Ed.2d 606) (1996). Further, the right of ‘access to courts’ ‘does not guarantee inmates the wherewithal to transform themselves into litigating engines capable of filing everything from shareholder derivative actions to slip-and-fall claims. The tools it requires to be provided are those that the inmates need in order to attack their sentences, directly or collaterally, and in order to challenge the conditions of their confinement. Impairment of any other litigating capacity is simply one of the