LEWIS, DIRECTOR, ARIZONA DEPARTMENT OF CORRECTIONS, et al. – Appellant
Versus
CASEY et al. , (1996) – Respondent
LEWIS, DIRECTOR, ARIZONA DEPARTMENT OF CORRECTIONS, et al. v. CASEY et al., (1996)
No. 94-1511
Argued: November 29, 1995 Decided: June 24, 1996
Respondents, who are inmates of various prisons operated by the Arizona Department of Corrections (ADOC), brought a class action against petitioners, ADOC officials, alleging that petitioners were furnishing them with inadequate legal research facilities and thereby depriving them of their right of access to the courts, in violation of Bounds v. Smith,
Held:
The success of respondents systemic challenge was dependent on their ability to show widespread actual injury, and the District Courts failure to identify anything more than isolated instances of actual injury renders its finding of a systemic Bounds violation invalid. Pp. 3-20.
(a) Bounds did not create an abstract, free-standing right to a law library or legal assistance; rather, the right that Bounds acknowledged was the right of access to the courts. E.g.,
(b) Statements in Bounds suggesting that prison authorities must also enable the prisoner to discover grievances, and to litigate effectively once in court, id., at 825-826, and n. 14, have no antecedent in this Courts pre-Bounds cases, and are now disclaimed. Moreover, Bounds does not guarantee inmates the wherewithal to file any and every type of legal claim, but requires only that they be provided with the tools to attack their sentences, directly or collaterally, and to challenge the conditions of their confinement. Pp. 9-11.
It found that ADOCs failures with respect to illiterate prisoners had resulted in the dismissal with prejudice of inmate Bartholics lawsuit and the inability of inmate Harris to file a legal action. Pp. 11-12.
(d) These findings as to injury do not support the systemwide injunction ordered by the District Court. The remedy must be limited to the inadequacy that produced the injury-in-fact that the plaintiff has established; that this is a class action changes nothing, for even named plaintiffs in a class action must show that they personally have been injured, see, e.g., Simon v. Eastern Ky. Welfare Tights Organization,
(e) There are further reasons why the order here cannot stand. In concluding that ADOCs restrictions on lockdown inma