How have the courts interpreted a motion alleging that a defendant was denied access to the courts during a search of his cell?

Finally, we address appellant's denial of access to courts claim. Appellant alleged that during the search of his cell, guards confiscated certain legal materials related to ongoing litigation. Specifically, appellant alleged that he was missing material he was compiling for a magistrate and two "very important" letters. Under Haines v. Kerner, 404 U.S. 519 (1972), federal courts are to give a liberal construction to pro se complaints and liberally construing appellant's complaint, he alleged that the seizure of these documents amounted to a denial of his access to the courts. In dismissing the complaint the district court ruled that appellant had not "presented any evidence demonstrating how the alleged seizure impaired his ability to seek redress in the courts." Accordingly, the court ruled that appellant had failed to controvert appellees' assertion that he had adequate access.