Lewis v. Casey

In Lewis v. Casey (1996) 518 U.S. 343, the United States Supreme Court clarified its holding in Bounds. There, the court held "'meaningful access to the courts is the touchstone.'" (Lewis, supra, 518 U.S. at p. 351.) The course of conduct mandated in Bounds, i.e. providing a prison law library or legal assistance programs, was "merely 'one constitutionally acceptable method to assure meaningful access to the courts'" and did "'not foreclose alternative means to achieve that goal.'" (Ibid.) Thus, while prisons were constitutionally required to provide inmates with meaningful access to the courts, they were not required to do so in any particular manner. (See id. at p. 352.) Lewis also required an inmate alleging denial of meaningful access to the courts to show that the prison's conduct caused him "actual injury," or "'actual prejudice with respect to contemplated or existing litigation, such as the inability to meet a filing deadline or to present a claim.'" (Lewis, supra, 518 U.S. at p. 349.) The Constitution does not require prisons enable its inmates to "discover grievances" or "to litigate effectively once in court." (Ibid.) Importantly, an inmate's right of meaningful access to courts was limited to three types of claims: direct appeals, habeas petitions, or actions under 42 United States Code section 1983 challenging conditions of confinement. (Ibid.) "Impairment of any other litigating capacity is simply one of the incidental (and perfectly constitutional) consequences of conviction and incarceration." (Id. at p. 355.)