THIS NOTE EXAMINES CIRCUMSTANCES IN WHICH THE POSSIBILITY OF A PRO SE DEFENSE WHICH IS SIGNIFICANTLY INFERIOR TO WHAT MAY BE EXPECTED OF THE PROSECUTION, BECOMES ALMOST A CERTAINTY. THE SITUATION IS ONE IN WHICH A DEFENDANT WHO CHOOSES TO REPRESENT HIMSELF IS JAILED BEFORE TRIAL. PRETRIAL INCARCERATION WILL CAUSE A DEFENDANT TO PRESENT AN INADEQUATE DEFENSE BECAUSE IT PREVENTS EFFECTIVE DEFENSE PREPARATION, AS FEW JAILS PROVIDE EITHER ACCESS TO LEGAL RESEARCH MATERIALS OR THE MEANS TO INVESTIGATE FACTUAL ASPECTS OF THE CASE TO PRETRIAL DETAINEES. THIS NOTE ARGUES THAT THERE EXISTS A DUE PROCESS RIGHT TO AN ADEQUATE OPPORTUNITY TO PREPARE. WHEN A DEFENDANT EXERCISES HIS RIGHT OF SELF-REPRESENTATION, HE DOES NOT WAIVE THIS RIGHT TO PREPARE, AND THUS, IF THE STATE RESTRICTS A PRO SE DEFENDANT'S PREPARATION BY JAILING HIM BEFORE TRIAL, IT MUST PROVIDE ALTERNATIVE MEANS OF PREPARING A DEFENSE. A PRACTICAL ALTERNATIVE MEANS OF PREPARING A DEFENSE IS SUGGESTED AND THAT IS THE APPOINTMENT OF STANDBY COUNSEL TO AID THE DETAINEE IN HIS TRIAL PREPARATION. (AUTHOR ABSTRACT MODIFIED)...EB