Minnesota State Law Library
PART I: Bounds
PART II: Lewis
Part I of the bibliography lists articles and court decisions that describe what is meant by "meaningful access to the courts" in the context of providing law library services (not assistance by person trained in the law) in correctional settings in light of the landmark Supreme Court decision Bounds v. Smith. In general it includes representative materials that address different elements of prison law library service and that give practical guidance in setting up or providing these services.
The first section of PART I is an alphabetical list of selected articles and books. The second section is a chronological list of selected court cases.
PART I, SECTION I
American Association of Law Libraries, Social Responsibilities Special Interest Section. Standing Committee on Law Library Service to Institution Residents. Recommended Collections for Prison and Other Institution Law Libraries. Chicago: AALL, 1996.
American Correctional Association. Standards for Adult Correctional Institutions. 3d ed. Standards 3-4262 through 3-4264, 3-4256. College Park, MD: ACA, 1990.
American Correctional Association. Standards for Adult Local Detention Facilities. 3d ed. Standards 3E-01 through 3E-03, 3D-18. College Park, MD: ACA, 1991.
Botta, Jean Clancy. "Inmate Access to the Courts and More Through New York State's Prison Law Libraries." The Bookmark 48 (Summer 1990): 296-299.
Bowden, Anne R. "North Carolina County Jail Inmates' Right to Access Courts." North Carolina Law Review, 66 (March 1988): 583-601.
Brakel, Samuel Jan. "'Mastering' the Legal Access Rights of Prison Inmates." New England Journal on Criminal & Civil Confinement, 12 (Winter 1986): 1-69.
Director, Jerald J. "Relief Under Federal Civil Rights Acts to State Prisoners Complaining of Interference With Access to Courts," ALR Federal 23 (1975): 1-143.
Ducey, Richard E. "Survey of Prisoner Access to the Courts: Local Experimentation a' Bounds," New England Journal on Criminal & Civil Confinement 9 (Winter 1983): 47-123.
Flores, Arturo A. "Bounds and Reality: Lawbooks Alone Do Not a Lawyer Make," Law Library Journal 77 (1984-85): 275-287.
Flores, Arturo A. Manual for Prison Law Libraries, 2d ed. AALL Publication Series, no. 36. Littleton, CO: Rothman, 1989.
George, James B. "Legal Status of Prisoners." In American Bar Association Standards for Criminal Justice, Sec. 23-2.3. Boston: Little, Brown, 1981.
Hinckley, Steven D. "Bounds and Beyond: A Need to Reevaluate the Right of Prisoner Access to the Courts," University of Richmond Law Review 22 (Fall 1987): 19-49.
Hotchkiss, Carolyn (revised by Marianne Yen & Jeffra Becknell). "Your Right to Learn the Law: Jailhouse Lawyers and Law Libraries." In A Jailhouse Lawyer's Manual, 3d ed., Chapter 3. New York: Columbia Human Rights Law Review, 1992.
Ihrig, Jay M. "Providing Legal Access." In Libraries Inside: A Practical Guide for Prison Librarians, 195-204. Jefferson, N.C.: McFarland, 1995.
Mushlin, Michael B. "Access to the Courts." In Rights of Prisoners, 2d ed., section 11.04. New York: McGraw-Hill, 1993.
Ryan, Wayne. "Access to the Courts: Prisoners' Right to a Law Library," Howard Law Journal 26 (1983): 91-117.
St. Sauver-Reinecke, Barbara. "Assisting Prisoners: Reference Guidelines at Kratter Law Library, University of San Diego." Law Library Journal 75 (Fall 1982): 529-535.
Smith, Christopher E. "Examining the Boundaries of Bounds: Prison Law Libraries and Access to the Courts," Howard Law Journal 30 (Winter 1987): 27-44.
Smith, Christopher E. "Improving the Use of Prison Law Libraries: A Modest Proposal," Law Library Journal 79 (Spring 1987): 227-239.
Swenson, Karen B. "John L. v. Betty Adams: Taking Bounds in the Right Direction for Incarcerated Juveniles," Memphis State University Law Review 24 (Spring 1994): 429-489.
Teitelbaum, Gene. Inspecting a Prison Law Library. Homes Beach, FL: Gaunt & Sons, 1989.
U.S. Department of Justice. Federal Standards for Prisons and Jails: December 16, 1980. Standards 1.03 through 1.05. Washington, D.C.: Government Printing Office, 1981.
PART I, SECTION II
Smith v. Bounds, 538 F.2d 541 (4th Cir. 1975), aff'd Bounds v. Smith, 430 U.S. 817, 97 S.Ct. 1491, 52 L.Ed.2d 72 (1977).
Landmark case which states that prison authorities must 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."
O'Bryan v. County of Saginaw, Michigan, 437 F. Supp. 582 (E.D. Mich. 1977).
Jail authorities must provide pre-trial detainees meaningful access to the courts.
Fluhr v. Roberts, 460 F. Supp. 536 (W.D. Ky. 1978).
Limited county jail collection which is supplemented by interlibrary loan program with local law library is adequate.
Williams v. Leeke, 584 F.2d 1336 (4th Cir. 1978), cert. den. 442 U.S. 911 (1979).
Maximum security inmates who were not allowed in law library but who could request counsel were not denied access. Misdemeanants serving sentences of up to twelve months in local jail are entitled to reasonable access to courts.
Rhodes v. Robinson, 612 F.2d 766 (3d Cir. 1979).
Premise that a prison law library may never discard a law book, even if the book is replaced with a more current volume, has no arguable support in the Constitution or federal law.
Martin v. Phelps, 380 So.2d 164 (La. App. 1979).
Inmate housed at "outcamp" several miles from main prison complex was not denied access where indirect access to library and opportunity to consult with "counsel substitute" was provided.
Kelsey v State of Minnesota, 622 F.2d 956 (8th Cir. 1980).
Although state prison law library's inventory, updating, and irregular hours of access were inadequate, no denial of access to the courts found where alternative means were available.
Leeds v. Watson, 630 F.2d 674 (9th Cir. 1980).
It is the responsibility of jail personnel to inform inmates of availability of legal research material or how to go about obtaining a court order permitting its use.
People v. George, 406 N.E.2d 936 (Ill. 1980).
Pretrial pro se detainee has no right to select the form access to legal materials is to take. Appointment of public defender satisfies meaningful access requirement.
Jensen v. Satran, 303 N.W.2d 568 (N.D. 1981).
Prison core collection adequate with additional access to State Law Library materials and law library hours (30 per week) did not restrict inmate so as to deny fundamental right of access to the courts.
Canterino v. Wilson, 538 F. Supp. 62 (W.D. Ky. 1982).
Inmate legal assistance in addition to equivalent law library facilities was necessary to provide equal opportunities to female inmates.
Cepulonis v. Fair, 563 F. Supp. 659 (D. Mass. 1983), aff'd in part, vac'd in part & remanded 732 F.2d 1 (1st Cir. 1984).
Inmates in Departmental Segregation Unit (the most secure unit in Mass. correctional system) must also have access to the courts and such access does not mandate additional legal assistance when law library access is adequate.
Corgain v. Miller, 708 F.2d 1241 (7th Cir. 1983).
State inmates in federal prison had the right to access state legal materials, however there was no duty to provide such prisoners with state law libraries in the event they chose not to accept adequate alternative services.
Brown v. Smith, 580 F. Supp. 1576 (M.D. Penn. 1984).
Federal prisons are not responsible for providing state legal materials. Transferring state is responsible for providing adequate law library or adequate assistance from persons trained in law of transferring state.
Toussaint v. McCarthy, 597 F. Supp. 1388 (N.D. Cal. 1984), aff'd in part, rev'd in part and vac'd in part 926 F.2d 800 (9th Cir. 1990).
System for "paging" books for segregated inmates is constitutionally deficient.
Brown v. Manning, 630 F. Supp. 391 (E.D. Wash. 1985).
Mandates law library service or trained legal assistance for indigent persons imprisoned for more than three days in the county jail.
Morrow v. Harwell, 768 F.2d 619 (5th Cir. 1985), on remand 640 F.Supp. 225 (W.D. Tex. 1986).
County's bookmobile service accompanied by circumscribed assistance from law students or certified paralegals deemed adequate.
Lindquist v. Idaho State Board of Corrections, 776 F.2d 851 (9th Cir. 1985).
Addresses questions of minimum standards, hours, and inmate illiteracy.
Berry v. Department of Corrections, 697 P.2d 711 (Ariz. App. 1985).
Mandates law library service or trained legal assistance for prisoners held for sixty to ninety days in a diagnostic facility prior to being transferred to permanent prison.
Giarratano v. Murray, 668 F.Supp. 511 (E.D. Va. 1986), aff'd in part, rev'd in part 836 F.2d 1421 (4th Cir. 1988), aff'd 847 F.2d 1118 (4th Cir. 1988), rev'd & remanded 492 U.S. 1 (1989).
Where death row inmates were incapable of effectively using law books to raise their postconviction claims and where attorneys were not assigned to work full-time and performed no factual inquiries, meaningful access standard was not met.
Campbell v. Miller, 787 F.2d 217 (7th Cir. 1986).
Security status of federal inmate may justify reasonable steps restricting his direct access to legal materials. Regulation requiring "exact-cite" deemed reasonable.
U.S. ex rel. Para-Professional Law Clinic v. Kane, 656 F. Supp. 1099 (D.C. Pa. 1987), aff'd 835 F.2d 285 (3rd Cir. 1987).
Closing inmate-formed clinic violates the constitutional rights of segregated and functionally illiterate prisoners even where law library is adequate.
Straub v. Monge, 815 F.2d 1467 (11th Cir. 1987).
"Catch-22" requiring court order to gain access to legal materials for non-indigent inmate pursuing civil matter unconstitutional. Right of meaningful access to courts applies in civil forfeiture actions.
Flittie v. Solem, 827 F.2d 276 (8th Cir. 1987).
Restricted access to library following dismissal of inmate from prison law library clerk position ruled reasonable.
Eldridge v. Block, 832 F.2d 1132 (9th Cir. 1987).
County jail inmate on extradition hold entitled to access law library.
Gluth v. Kangas, 773 F. Supp. 1309 (D. Ariz. 1988), aff'd 951 F.2d 1504 (9th Cir. 1991).
Addresses policies of inmate legal assistance training, legal supplies, institutional photocopying, and hours of actual library use.
DeMallory v. Cullen, 855 F.2d 442 (7th Cir. 1988).
Dependence on untrained inmate paralegals as alternative to library access does not provide sufficient access to the courts.
Coleman v. State, 762 P.2d 814 (Idaho 1988).
Regulation denying inmates on detention status access to the law library failed to establish legitimate penological interests served by the rule and is unconstitutional.
Hambrick v. Davies, 711 F. Supp. 884 (E.D. Ky. 1989), aff'd in part and vac'd in part 886 F.2d 1315 (6th Cir. 1989).
Inmate who declined transfer to another facility with adequate law library did not have "access to courts" claim.
Watson v. Norris, 729 F. Supp. 581 (M.D. Tenn. 1989).
Law library access for persons in protective segregation was too limited when it relied on "remote control" system and when response to calls for assistance rested in the sole discretion of "jailhouse lawyers."
Griffin v. Coughlin, 743 F. Supp. 1006 (N.D. N.Y. 1990).
Book request system for protective custody inmates did not provide meaningful access to the courts because inmates were not able to browse, they experienced delays in receiving books, and requests for citation checks were often completed improperly.
Housley v. Killinger, 747 F. Supp. 1405 (D. Or. 1990), aff'd 972 F.2d 1339 (9th Cir. 1992).
Where federal prison law library had adequate resources including paper, pens and notarial services, the library was open more than 40 hours per week and stamps were available free of charge to indigent inmates, inmate failed to establish that he was denied meaningful access.
John L. v. Adams, 750 F. Supp. 288 (M.D. Tenn. 1990), aff'd in part, rev'd in part 969 F.2d 228 (6th Cir. 1992).
Incarcerated juveniles' constitutional right of access to courts entitled them to access to attorney; merely providing access to law library would fail to assure meaningful access.
U.S. v. Robinson, 913 F.2d 712 (9th Cir. 1990), aff'd 12 F.3d 1110 (9th Cir, 1993).
Defendant who is represented by counsel has no constitutional right of access to legal materials, and there is nothing constitutionally offensive about requiring defendant to choose between appointed counsel and access to legal materials.
Vaughn v. U.S., 579 A.2d 170 (D.C. App. 1990).
Lack of jail law library alone does not prove denial of access to the courts.
Geder v. Roth, 765 F. Supp. 1357 (N.D. Ill. 1991).
Unlimited access to law library by pro se is not required, and some demonstration of prejudice to inmate is necessary to establish denial of meaningful access to courts.
Nolley v. County of Erie, 776 F. Supp. 715 (W.D. N.Y. 1991).
Inmate infected with HIV was denied her constitutional right of access to courts when ad hoc policy was applied to deny her direct access to law library books and to deny her face-to-face contact with inmate law clerks.
Chandler v. Baird, 926 F.2d 1057 (11th Cir. 1991).
Where alleged deprivations are of minor and short-lived nature and do not implicate general policies Bounds requires some showing of prejudice or injury to support a claim on denial of access.
Johnson v. Moore, 948 F.2d 517 (9th Cir. 1991).
Incomplete U.S.Code set in law library is not a violation of adequate access, and claim failed to show either actual injury or inadequate law library or alternative legal assistance.
Shoats v. Commissioner, PA Department of Corrections, 591 A.2d 326 (Pa. Cmwlth. 1991).
Transferring state is responsible for providing access to state legal materials even if transfer to federal facility is temporary.
Miller v. Evans, 832 P.2d 786 (Nev. 1992).
System of satellite law libraries, inmate law clerks and interlibrary loan with the Nevada Supreme Court provides inmates with a constitutional basis for meaningful access to the courts.
Petrick v. Maynard, 11 F.3d 991 (10th Cir. 1993).
Failure to provide foreign state legal materials to attack prior convictions used to enhance sentence is denial of meaningful access.
Allen v. City and County of Honolulu, 816 F. Supp. 1501 (D. Hawaii 1993), aff'd 39 F.3d 936 (9th Cir. 1994).
Forcing a prisoner to choose between law library access and outdoor recreation is denial of constitutional right.
Martin v. Ezeagu, 816 F. Supp. 20 (D. D.C. 1993).
Law librarian not entitled to qualified immunity where plaintiff alleges an ongoing pattern of denial of access, including ejecting plaintiff from library without justification, locking plaintiff out of the library, berating, hounding and shouting racial epithets at plaintiff and using profanity when addressing plaintiff.
Oswald v. Graves, 819 F. Supp. 680 (E.D. Mich. 1993).
Prison librarian entitled to defense of qualified immunity; inmate had no clearly established statutory or constitutional right to free photocopying or specific amount of time in library.
Acevedo v. Forcinito, 820 F. Supp. 886 (D. N.J. 1993).
Merely making law library available to non-English speaking prisoner does not satisfy duty of prison officials to provide meaningful access.
Howard v. Parkman, 437 S.E.2d 483 (Ga. App. 1993).
County jail records showing that inmate received more than 4,000 copies in six-month period along with plaintiff's concession that he is permitted to work in law library five hours per week indicate that plaintiff was provided with adequate access to a law library.
Canell v. Bradshaw, 840 F. Supp. 1382 (D. Or. 1993).
Inmates temporarily housed at intake center have constitutional right of access to courts, and "paging system" does not provide adequate access to courts.
Alston v. DeBruyn, 13 F.3d 1036 (7th Cir. 1994).
No requirement to show actual injury when direct, substantial and continuous limits on access to legal materials is alleged.
Lloyd v. Corrections Corp. of American, 855 F. Supp. 221 (W.D. Tenn. 1994).
Inmate's access to the courts was adequate where he was represented by counsel, even if he was denied access to law library. Also, employees of privately operated penal facilities do not act "under color of state law" for purposes of Section 1983 claims.
Vandelft v. Moses, 31 F.3d 794 (9th Cir. 1994).
Prison officials may restrict access to library for segregated inmate in protective custody. Inmate must show inadequate access caused actual injury.
Cornett v. Donovan, 51 F.3d 894 (9th Cir. 1995), cert. den. 116 S.Ct. 2580 (1996).
Right of access to courts is guaranteed to people who are involuntarily committed to mental institution, regardless of whether they are civilly committed following criminal proceedings or civilly committed on grounds of dangerousness.
Boyd v. Wood, 52 F.3d 820 (9th Cir. 1995).
Sending state authorities maintain responsibility for providing state legal materials to their prisoners incarcerated in out-of-state facilities.
Schrier v. Halford, 60 F.3d 1309 (8th Cir. 1995).
Affirmative assistance from the state doesn't extend to inmate's pursuit of general civil actions.
Brooks v. Buscher, 62 F.3d 176 (7th Cir. 1995).
Prison officials may restrict direct access to library materials for dangerous inmate.
PART II, SECTION I
Blum, George L. “Sufficiency of Access to Legal Research Facilities Afforded Defendant. Confined in State Prison or Local Jail.” ALR 5th 98 (2002): 445-531.
Gerken, Joseph L. "Does Lewis v. Casey Spell the End to Court-Ordered Improvement of Prison Law Libraries?" Law Library Journal 95 (Fall 2003): 491-513.
Schwartz, Martin A. "Section 1983 litigation," Touro Law Review 13 (Winter 1997): 312-336.
Steinberger, David. "Lewis v. Casey: Tightening the Boundaries of Prisoner Access to the Courts?" Pace Law Review 18 (1998): 377-417.
Vogel, Brenda. "Bailing Out Prison Libraries," Library Journal, November 15, 1997, 35-37.
Wilhelmus, David W. “Where Have All the Law Libraries Gone?: Offenders' Rights to Access the Courts in the Wake of Casey vs. Lewis.” Corrections Today, December 1999, 122-153.
PART II, SECTION II
Casey v. Lewis, 834 F.Supp. 1553 (D.Ariz. 1992), aff'd in part, vac'd in part and rem'd 43 F.3d 1261 (9th Cir. 1994), rev'd and rem'd sub nom. Lewis v. Casey, 116 S.Ct. 2174, 135 L.Ed.2d 606 (1996).
Significant decision stating that Bounds did not create an abstract, free-standing right to a law library or legal assistance; rather, the constitutional right is "access to the courts." The manner in which access is provided is left to the discretion of corrections officials. This right is limited to nonfrivolous lawsuits that attack prison sentences or challenge the conditions of confinement. In claiming denial of "access to the courts", the inmate must show "actual injury." Establishing that his prison's law library or legal assistance program is sub-par in some theoretical sense is not enough. The remedy is limited to the inadequacy that produced the injury-in-fact that the plaintiff establishes.
Pilgrim v. Littlefield, 92 F.3d 413 (6th Cir. 1996).
Pro se prisoners must demonstrate that inadequacy of the prison law library or legal assistance caused actual injury.
Stotts v. Salas, 938 F. Supp. 663 (D.Hawaii 1996).
A transferred inmate must show that refusal to send law books from home state caused an actual injury. Also, 21-day confiscation of inmate's legal materials upon placement of inmate in lockdown for allegedly assaulting another inmate did not result in actual injury so as to rise to level of constitutional violation, despite claims that deprivation resulted in dismissal of six amended motions.
Penrod v. Zavaras, 94 F.3d 1399 (10th Cir. 1996).
Limits on unassigned prisoners' access to law library not unreasonable or constitutionally impermissible.
Casteel v. Pieschek, 944 F. Supp. 748 (E.D.Wis. 1996).
Weekly access to law library materials and letter access to legal assistance organizations for jail inmates is sufficient.
Sabers v. Delano, 100 F.3d 82 (8th Cir. 1996).
Female inmate must show actual injury due to attorney shortcomings or the lack of a law library, even if the denial of access is systemic. Absent standing to bring the claim in her own right, inmate is not eligible to represent a class of persons raising the same claim.
Rowbottom v. State, 938 S.W.2d 224 (Ark. 1997).
Trial court is free to appoint standby counsel instead of granting access to a law library. Plaintiff failed to show how appointment of standby counsel caused actual injury.
Riley v. Coutu, 172 F.R.D. 224 (E.D.Mich. 1997).
Lewis decision did not change the standard long followed in the Sixth Circuit that requires a showing of actual injury.
Davie v. Wingard, 958 F. Supp. 1244 (S.D.Ohio 1997).
Although inmate offered evidence of actual injury because prison's inadequate library left him unaware of certain court rules, he did not state claim for violation of his right to access to the courts. Even if inadequacy were below constitutional standards he did not allege that any individual official knew of condition of the materials and deliberately deprived him of access.
Amen-Ra v. Department of Defense, 961 F. Supp. 256 (D.Kan. 1997).
Inmates of U.S. Disciplinary Barracks made no showing that difficulty accessing the law library because its hours of operation conflicted with educational and recreational programs prevented them from pursuing a claim due to inability to obtain library materials.
Ingalls v. Florio, 968 F. Supp. 193 (D.N.J. 1997).
County inmate claimed that not being able to go to law library, or not go as often as desired impaired his ability to assist defense counsel. This complaint failed to state an actual injury caused by law library limitations.
Jones v. City and County of San Francisco, 976 F. Supp. 896 (N.D.Cal. 1997).
Law Library materials and assistance remain inadequate for non-English speakers, yet plaintiffs did not point to any inmate who has alleged that these inadequacies have actually hindered his efforts to pursue a legal claim.
Ladd v. Hannigan, 962 F. Supp. 1390 (D.Kan. 1997).
Inmate's failure to obtain a library card, his failure to appear for emergency requested library time, and failure to do only his own research while in the library showed that the inmate impaired his ability to research his own case.
Counts v. Newhart, 951 F. Supp. 579 (E.D.Va. 1996), aff'd 116 F.3d 1473 (4th Cir. 1997).
Because plaintiff has not alleged any specific injury, he has not satisfied the threshold requirement of an access-to-courts claim, regardless of the adequacy of the jail's law library or the length of his detention in the city jail.
Klinger v. Department of Corrections, 107 F.3d 609 (8th Cir. 1997).
Even though plaintiffs did show a complete and systemic denial of access to a law library or legal assistance prior to January 1989, none of the inmates suffered actual injury or prejudice and therefore the claim fails.
Demps v. State, 696 S.2d. 1296 (Florida 1997).
Transferring state needs to provide state statutes and materials and/or assistance from person trained in the law for inmate to file postconviction from that state.
Farver v. Vilches, 155 F.3d 978 (8th Cir. 1998).
Discipline of jail inmate resulting in loss of law library privileges for one day does not rise to the level of denial of access to the courts when no actual injury or prejudice is demonstrated.
Wilson v. Blankenship, 163 F3d. 1284 (11th Cir. 1998).
Federal prisoner housed at county jail did not have claim of inadequate access against warden where the warden had no authority, ability, or funds to offer library services.
McConico v. Martin, 716 So.2d 222 (Ala.Civ.App. 1998).
Inmate does not have standing, or the right, to sue simply because he was not provided access to the law library or that the law library is sub-par in some theoretical sense. Actual injury must be shown.
Lambros v. Hawk, 993 F.Supp. 1372 (D.Kan. 1998).
Federal inmate's right of access to the courts does not require English translations of Brazilian laws. Plaintiff did not show that the shortcomings caused actual injury.
Arce v. Walker, 58 F.Supp.2d 39 (W.D.N.Y. 1999).
Eighteen-day denial of access to law library did not impair access to courts, especially where no actual injury was claimed. Defendants' motion for summary judgment granted and complaint dismissed.
Jones v. Greninger, 188 F.3d 322 (5th Cir. 1999).
Limiting access to five hours a week as a result of a job reassignment does not violate right of access to the court.
State v. Brockenshire, 995 P.2d 905 (Kan.App. 2000).
Pre-trial detainees access to law library materials only through public defender is not denial of access to courts where plaintiff has not shown actual injury.
Benjamin v. Kerik, 102 F.Supp.2d 157 (S.D.N.Y. 2000).
Provisions of consent decree relating to law libraries in the defendants' prisons are terminated under the Prison Litigation Reform Act of 1995 as there was no showing of actual injury.
Gilmore v People of the State of California, 220 F.3d 987 (9th Cir. 2000).
First-generation prison condition case Gilmore v. Lynch, 319 F.Supp. 105 (1970) led to consent decree regarding law library collections and access among other conditions. This case reverses and remands lower court decision terminating the consent decrees under PLRA because lower court placed burden on plaintiffs to show that the consent decree was not terminable and because lower court denied plaintiffs' request for evidentiary hearing to show that law library limits caused actual injury.
Gomez v Vernon, 255 F.3d 1118 (9th Cir. 2001).
Affirmation of lower court magistrate's order granting relief to inmate law clerks who claim that they were retaliated against for providing law library assistance and helping other inmates in filing actions.
McBride v. Deer, 240 F.3d 1287 (10th Cir. 2001).
Inmate's statement that he lost his appeal because he was denied law library materials failed to allege sufficient facts to satisfy the actual injury requirement. For example, he did not describe the legal materials he was seeking, and he did not explain that his legal claim was nonfrivolous.
This annual bibliography is compiled by the Outreach Services staff of the Minnesota State Law Library. We acknowledge the assistance of interns Jennifer M. Cich in 1988, Diane L. Thompson in 1990, Mark Tolbert in 1994, Bob Maxfield in 1995, Aida Picardal in 1996, Mary Keller in 2001 and Lisa Marohn in 2002.