What is the current state of the law regarding access to professional representation in prison?

In Ching v. Lewis, 895 F.2d 608, 609 (9th Cir.1990), we held that "policies will not be upheld if they unnecessarily abridge the defendant's meaningful access to his attorney and the courts," and that "the opportunity to communicate privately with an attorney is an important part of that meaningful access." See also Procunier v. Martinez, 416 U.S. 396, 419, 94 S.Ct. 1800, 1814, 40 L.Ed.2d 224 (1974) ("Regulations and practices that unjustifiably obstruct the availability of professional representation ... are invalid."). Because an inmate's access to his attorney is inextricably tied to his meaningful access to

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