The following excerpt is from Kambon v. Cal. Dep't of Corr. & Rehab., No. 12-cv-2651 KJM KJN P (E.D. Cal. 2013):
Plaintiff alleges that the confiscation of his legal property and photograph violated his right to access the courts. To establish a violation of the right of access to the courts, a prisoner must establish that he has suffered an actual injury. Lewis v. Casey, 518 U.S. 343, 349 (1996). An "actual injury" is "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.
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