In Christopher v. Harbury (2002) U.S. 122 S.Ct. 2179, the Supreme Court held a "denial of access to courts" case under 42 U.S.C. section 1983 cannot stand alone but must be based on a valid underlying cause of action that is rendered ineffective by the wrongful actions of a public official. (Id. at pp. 2186-2187.) The City argues if the Garcias fail to prove estoppel, they will not be able to prove that a cover-up caused the loss of the wrongful death cause of action because they rely on the same facts for both. In Christopher, however, the plaintiff's state law cause of action existed independently from the denial of access cause of action. As the court remarked, "There is, after all, no point in spending time and money to establish the facts constituting denial of access when a plaintiff would end up just as well off after litigating a simpler case without the denial-of-access element."(Id. at p. 2187.)