Lewis v. Casey - 518 U.S. 343, 116 S. Ct. 2174 (1996)

Rule:

Because Bounds did not create an abstract, freestanding right to a law library or legal assistance, 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. Insofar as the right vindicated by Bounds is concerned, meaningful 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.

Facts:

In Bounds v Smith (1977) 430 US 817, 52 L Ed 2d 72, 97 S Ct 1491, the United States Supreme Court held that the fundamental federal constitutional right of access to the courts required prison authorities to assist inmates in the preparation and filing of meaningful legal papers by providing the inmates with adequate law libraries or adequate assistance from persons trained in the law. In 1990, 22 inmates of various prisons operated by the Arizona department of corrections filed a class action in the United States District Court for the District of Arizona against Arizona prison authorities. The inmates alleged that the authorities were depriving them of their constitutional right of access to the courts. Following a bench trial, the District Court ruled that the prison system failed to comply with constitutional standards with respect to access to the courts in a number of areas relating to the adequacy and availability of law libraries and legal assistance programs; and two groups of inmates--prisoners in lockdown and illiterate or non-English-speaking inmates--were particularly affected by the inadequacies of the system. The District Court also appointed a special master to investigate and report about appropriate relief. Thereafter, the District Court adopted, without substantial change, the special master's proposed permanent injunction, which mandated detailed changes with respect to the prison system's law libraries and legal assistance programs. The United States Court of Appeals for the Ninth Circuit refused to grant the prison authorities' application for a stay of the injunction, but the Supreme Court granted such a stay pending the filing and disposition of a petition for a writ of certiorari. On the merits of the authorities' appeal, the Court of Appeals affirmed the terms of the injunction with minor exceptions.

Issue:

Did the district court err in issuing an injunctive order which mandated a systemwide relief?

Answer:

Yes.

Conclusion:

The Court found that actual injury was required to establish standing for a violation of constitutional rights, which meant a showing that the inmates were denied the tools required to attack their sentences, directly or collaterally, or to challenge conditions of their confinement. Apart from the district court's identification of two instances of actual injury to two inmates, there was no evidence that illiterate prisoners could not obtain the minimal help necessary to file claims. Thus, the district court's granting of a systemwide remedy improperly went beyond what was necessary to provide relief to the two inmates. The Court also found that the district court failed to accord adequate deference to the judgment of the prison authorities with respect to restrictions on lockdown prisoners' access to law libraries, that the injunction was inordinately intrusive, and that the order was developed through a process that failed to give adequate consideration to the views of state prison authorities.