In Payne v. Superior Court (1976) 17 Cal.3d 908, a prisoner sought to defend a civil suit for damages. He was unable to obtain counsel and, due to his incarceration, could not personally attend court proceedings. As a result, he suffered a default judgment. (Id. at pp. 911-912.) The court vacated the default, concluding that if the defendant were found indigent, he had a right to meaningful court access, either by appointment of counsel or by a continuance until he was free to defend the action himself. (Id. at pp. 912, 923-924.) The court reasoned that to defend his property rights, the prisoner had no alternative to the judicial forum into which he had been thrust, and his status as a prisoner foreclosed him from access, via personal appearance or by counsel. (Id. at pp. 917-918.) The court emphasized it was not ruling "that all indigents have a right to counsel in civil cases" or establishing "that indigent prisoners who are plaintiffs in civil actions may secure appointed counsel or the right to appear personally." (Id. at pp. 926-927.) The California Supreme Court held that an indigent prisoner seeking to defend a civil suit has a due process right of access to the courts. (Id. at p. 919.) The court noted that access to the courts does not entail a particular remedy, and could be accomplished either by appointed counsel or by personal appearance, among others. (Id. at p. 923.)