Can a plaintiff bring a claim for denial of access to the courts for reasons of frustration or hindrance?

Claims for denial of access to the courts may arise from the frustration or hindrance of "a litigating opportunity yet to be gained" (forward-looking claim) or from the loss of a meritorious suit that cannot now be tried (backward-looking claim). Christopher v. Harbury, 536 U.S. 403, 412-15 (2002). For backward-looking claims, plaintiff must identify the "non-frivolous, arguable underlying claim;" describe the official acts which frustrated his prior litigation; and "identify a remedy that may be awarded as recompense but not otherwise available in some suit that may yet be brought." Id. at 415 (citation and internal quotation marks omitted).

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