What is the test for a plaintiff to prove that a defendant has violated their First Amendment right of access to the courts by refusing to provide mail to an inmate?

MultiRegion, United States of America

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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