The following excerpt is from Gardner v. Stanislaus Cnty. Sheriff's Dep't, Case No. 1:17-cv-01369-DAD-JDP (E.D. Cal. 2019):
Isolated incidents of mail interference without any evidence of improper motive or resulting interference with the right to counsel or access to the courts do not give rise to a constitutional violation. See Meador v. Pleasant Valley State Prison, 312 F. App'x 954, 955 (9th Cir. 2009) (holding that prison officials' erroneous opening of one piece of legal mail "without a
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showing of actual injury or improper motive, cannot by itself establish a violation of his right of access to the courts"); Smith v. Maschner, 899 F.2d 940, 944 (10th Cir. 1990) (same).
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