Can the failure to properly process grievances be a violation of a prisoner's First Amendment right of access to the courts?

The failure to properly process grievances can, in some circumstances, violate a prisoner's First Amendment right of access to the courts. See Bradley v. Hall, 64 F.3d 1276, 1279 (9th Cir. 1995). This right is limited to direct criminal appeals, habeas petitions, and civil rights actions. Lewis v. Casey, 518 U.S. 343, 354 (1996). Claims for

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denial of access to the courts may arise from the frustration or hindrance of "a litigating opportunity yet to be gained" (forward-looking access claim) or from the loss of a meritorious suit that cannot now be tried (backward-looking claim). Christopher v. Harbury, 536 U.S. 403, 412-15 (2002). In either case, a plaintiff must show that he suffered an "actual injury" by being shut out of court. Lewis, 518 U.S. at 350-51. An "actual injury" is one that hinders the plaintiff's ability to pursue a legal claim. Id. at 351.