The following excerpt is from Quair v. CDCR HQ, No. 2:19-cv-1106 DB P (E.D. Cal. 2020):
Cir. 1999). To show actual injury, plaintiff must demonstrate that he suffered "actual prejudice with respect to contemplated or existing litigation, such as the inability to meet a filing deadline or to present a claim." Lewis, 518 U.S. at 348. Mere negligence is not sufficient to establish an unconstitutional denial of access to the courts. See Stevenson v. Koskey, 877 F.2d 1435, 1441 (9th Cir. 1989).
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