The following excerpt is from Hahn v. U.S., 917 F.2d 27 (9th Cir. 1990):
We have held that a prisoner who claims a denial of either an adequate law library or adequate legal assistance is not required to allege an actual injury to court access. However, if the prisoner's claims "do not involve such an allegation, the court must consider whether the plaintiff has alleged an 'actual injury' to court access." Sands v. Lewis, 886 F.2d 1166, 1179 (9th Cir.1989).
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