What is the test for a prisoner to obtain access to the courts?

MultiRegion, United States of America

The following excerpt is from Penton v. Dickinson, No. 2:11-cv-0518 KJN P (E.D. Cal. 2012):

Prisoners have a constitutionally protected right of meaningful access to the courts. Bounds v. Smith, 430 U.S. 817, 820-21 (1977). A prisoner claiming that his right of access to the courts has been violated must show that: 1) plaintiff's access was so limited as to

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