What are the requirements of a state to provide access to the courts for the purposes of a civil rights application?

States are required to assure all prisoners meaningful access to the courts. Bounds v. Smith, 430 U.S. 817, 824 (1977). For example, "indigent inmates must be provided at state expense with paper and pen to draft legal documents, with notarial services to authenticate them, and with stamps to mail them." Id. at 824-25. The inquiry is whether law libraries or other forms of legal assistance are needed to give prisoners a reasonably adequate opportunity to present claimed violations of fundamental constitutional rights to the courts. Id. at 825.

Plaintiff was also informed that an inmate bringing an access-to-courts case must allege actual injury in the pursuit of direct appeals, habeas petitions, and section 1983 civil rights actions to vindicate basic constitutional rights only. See Lewis v. Casey, 518 U.S. 343, 354 (1996). The injury requirement is not satisfied "by just any type of frustrated legal claim." Id. Examples of actual injury include having a case dismissed with prejudice and being unable to file legal actions. Id. at 355.

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B. Analysis