In Comeaux v. Thaler, Civil Action No. H-01-1411 (S.D. Tex. 2008), the court found that an inmate's complaint that he had inadequate access to the prison grievance process and sufficient legal supplies implicated the constitutional right to access to the courts.
"Prisoners clearly have a constitutionally protected right of access to the courts."
To establish a denial of access to the courts, however, a prisoner must demonstrate "actual injury" as a result of the alleged violative conduct.
In other words, he must establish that "his position as a litigant was prejudiced by his denial of access to the courts."