Does interference with access to counsel constitute interference with Access to Counsel?

Even assuming that plaintiff's inability to find counsel constitutes interference with "access to counsel," plaintiff's claim must be dismissed because he has not alleged that he suffered an actual injury as a result of the alleged deficiencies in the mail and phone systems. While plaintiff alleges that he was unable to post bail, recover his trailer home after it was towed, or make arrangements to repay a loan to his mother, he has not alleged that his inability to contact his mother or use the free phone line has hindered his effort to pursue a non-frivolous claim concerning his conviction or conditions of confinement. See Lewis v. Casey, 518 U.S. at 354-55. For example, plaintiff has not alleged that he missed a filing deadline or was unable to present a specific non-frivolous claim as a result of the alleged deprivations. See id. at 348-49.