Lewis v. Casey
Supreme Court of the United States
November 29, 1995, Argued ; June 24, 1996, Decided
[***614] [**2177] [*346] JUSTICE SCALIA delivered the opinion of the Court.
In Bounds v. Smith, 430 U.S. 817, 52 L. Ed. 2d 72, 97 S. Ct. 1491 (1977), we held that ] "the fundamental constitutional right of access to the courts [****5] requires prison authorities to assist inmates in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law." Id., at 828. Petitioners, who are officials of the Arizona Department of Corrections (ADOC), contend that the United States District Court for the District of Arizona erred in finding them in violation [****6] of Bounds, and that the court's remedial order exceeded lawful authority. [***615]
Respondents are 22 inmates of various prisons operated by ADOC. In January 1990, they filed this class action "on behalf of all adult prisoners who are or will be incarcerated by the State of Arizona Department of Corrections," App. 22, alleging that petitioners were "depriving [respondents] of their rights of access to the courts and counsel protected by the First, Sixth, and Fourteenth Amendments," id., at 34. Following a 3-month bench trial, the District Court ruled in favor of respondents, finding that "prisoners have a constitutional right of access to the courts that is adequate, effective and meaningful," 834 F. Supp. 1553, 1566 (Ariz. 1992), citing Bounds, supra, at 822, and that "[ADOC's] system fails to comply with constitutional standards," 834 F. Supp., at 1569. The court identified a variety of shortcomings of the ADOC system, in matters ranging from the training of [**2178] library staff, to the updating of legal materials, to the availability of photocopying services. In addition to these general [*347] findings, the court found that two groups of inmates were particularly affected by the system's [****7] inadequacies: "lockdown prisoners" (inmates segregated from the general prison population for disciplinary or security reasons), who "are routinely denied physical access to the law library" and "experience severe interference with their access to the courts," id., at 1556; and illiterate or non-English-speaking inmates, who do not receive adequate legal assistance, id., at 1558.
Having thus found liability, the court appointed a special master "to investigate and report about" the appropriate relief -- that is (in the court's view), "how best to accomplish the goal of constitutionally adequate inmate access to the courts." App. to Pet. for Cert. 87a. Following eight months of investigation, and some degree of consultation with both parties, the special master lodged with the court a proposed permanent injunction, which the court proceeded to adopt, substantially unchanged. The 25-page injunctive order, see id., at 61a-85a, mandated sweeping changes designed to ensure that ADOC would "provide meaningful access to the Courts for all present and future prisoners," id., at 61a. It specified in minute detail the times that libraries were to be kept open, the number of hours [****8] of library use to which each inmate was entitled (10 per week), the minimal educational requirements for prison librarians (a library science degree, law degree, or paralegal degree), the content of a videotaped legal-research course for inmates (to be prepared by persons appointed by the special master but funded by ADOC), and similar matters. Id., at 61a, 67a, 71a. The injunction addressed the court's concern for lockdown prisoners by ordering that "ADOC prisoners in all housing areas and custody levels shall be provided regular and comparable visits to the law library," except that such visits "may be postponed on an individual basis because of the prisoner's documented inability to use the law library without creating [*348] a threat to safety or security, or a physical condition if determined by medical personnel to prevent library use." Id., at 61a. With respect to illiterate and non-English-speaking inmates, the injunction declared that they were entitled to "direct assistance" from lawyers, paralegals, or "a sufficient number of [***616] at least minimally trained prisoner Legal Assistants"; it enjoined ADOC that "particular steps must be taken to locate and train bilingual prisoners [****9] to be Legal Assistants." Id., at 69a-70a.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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518 U.S. 343 *; 116 S. Ct. 2174 **; 135 L. Ed. 2d 606 ***; 1996 U.S. LEXIS 4220 ****; 64 U.S.L.W. 4587; 96 Cal. Daily Op. Service 4559; 96 Daily Journal DAR 7362; 10 Fla. L. Weekly Fed. S 39
SAMUEL A. LEWIS, DIRECTOR, ARIZONA DEPARTMENT OF CORRECTIONS, ET AL., PETITIONERS v. FLETCHER CASEY, JR., ET AL.
Prior History: [****1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.
Disposition: 43 F.3d 1261, reversed and remanded.
Bounds, inmates, courts, district court, cases, prison, law library, legal assistance, federal court, institutions, decree, access rights, illiterate, facilities, injunction, rights, Appeals, constitutional right, lockdown, parte, special master, invalidated, systemwide, regulation, actual injury, inadequacies, trained, affirmative obligation, appellate review, prison system
Civil Rights Law, Protection of Rights, Prisoner Rights, Access to Courts, Criminal Law & Procedure, Postconviction Proceedings, Imprisonment, General Overview, Constitutional Law, Case or Controversy, Standing, Civil Procedure, Judgments, Summary Judgment, Evidentiary Considerations, Burdens of Proof, Motions for Summary Judgment, Substantive Due Process, Scope, Contracts Law, Contract Formation, Consideration, Governments, Courts, Judicial Comity, State & Territorial Governments, Relations With Governments