What is the standard for determining liability for denial of access to the courts?

2 We do not rule upon the question whether "deliberate indifference" is the correct standard for determining liability for denial of access to the courts. See, e.g., Wood v. Housewright, 900 F.2d 1332, 1333-35 (9th Cir.1990) (applying deliberate indifference standard to Eighth Amendment violation where prison officials denied inmate medical attention, but not applying deliberate indifference standard to right-of-access claim). This case was tried on the assumption that "deliberate indifference" was the appropriate standard, and at oral argument of this appeal both parties stated that they did not contest the application of that standard. We therefore accept the "deliberate indifference" standard for purposes of our decision, without addressing its correctness.