The following excerpt is from Leonardelli v. Huston, 9 F.3d 1552 (9th Cir. 1993):
If an inmate does not claim a denial of access to adequate law libraries or legal assistance, he must show an actual injury: a specific instance in which he was actually denied access to the courts. Sands v. Lewis, 886 F.2d 1166, 1171 (9th Cir.1989). Indigent inmates must be provided with certain materials in order to have adequate access to the courts. See Bounds, 430 U.S. at 824-25; King v. Atiyeh, 814 F.2d 565, 568 (9th Cir.1987). States, however, may reasonably regulate the availability of materials indigent inmates need to access the courts. See King, 814 F.2d at 568.
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