The following excerpt is from Chatman v. Felker, No. 2:06-cv-2912-LKK-EFB P (E.D. Cal. 2013):
Prisoners enjoy a First Amendment right of access to the courts. Bounds, 430 U.S. at 821. To establish a violation of this right, a plaintiff must show that defendant's conduct caused actual injury to a non-frivolous legal claim. Lewis v. Casey, 518 U.S. 343, 348-53 (1996). Conduct that may cause actual injury includes the refusal to provide postage to an indigent inmate to mail legal documents or opening an inmate's legal mail outside his presence (although
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