The following excerpt is from Newman v. Brandon, Case No. 1:10-cv-00687 JLT (PC) (E.D. Cal. 2011):
Prisoners have a constitutional right under the First Amendment of access to the courts. Lewis v. Casey, 518 U.S. 343, 346 (1996). To plead a viable access to the courts claim, a prisoner must allege facts showing that the defendant's misconduct impeded the prisoner's ability to pursue a nonfrivolous legal claim that seeks to vindicate basic constitutional rights. Id. at 353-55. In other words, there must be some "actual injury" caused by defendant's actions "such as the inability to meet a filing deadline or to present a claim." Id. at 348.
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