Does a prisoner have a general 'right of access' to the courts in civil cases?

The majority's main premise, however, that indigent prisoners possess a general 'right of access' in the sense that they are entitled to free legal representation or their personal presence in civil courts, either or both, is incorrect under existing decisions of this state. Prisoners in California enjoy only a limited statutory degree of 'access' to the courts. This conclusion is consistent with Penal Code section 2600 which provides that prisoners are deprived of only those rights '. . . necessary in order to provide for the reasonable security of the institution . . . and for the reasonable protection of the public.' The right to appear personally in court is, of course, one which necessarily involves considerations of both institutional security and of public safety. Until now it had been assumed that a prisoner possessed no such right in civil actions. (Wood v. Superior Court (1974) 36 Cal.App.3d 811, 813, 112 Cal.Rptr. 157, and cases cited.) With respect to the asserted right to appointed counsel for prisoners in civil cases it is not accurate to say that prisoners are 'deprived' of such a right, for under existing law even nonprisoner indigents have no abstract

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