The following excerpt is from Saddozai v. Hosey, Case No. 1:19-cv-01611-DAD-JDP (E.D. Cal. 2020):
To show a violation of the right to access to the courts, an inmate must demonstrate "actual injury," identifying a "specific instance" in which he was denied access. Sands v. Lewis, 886F.2d 1166, 1171 (9th Cir. 1989); see also Lewis v. Casey, 518U.S. 343, 349 (1996). The injury requirement is "not satisfied by just any type of frustrated legal claim." Lewis, 518 U.S. at 354-55. It is only satisfied if an inmate is denied access with regard to a direct appeal from their conviction, habeas petitions, or civil rights actions challenging the conditions of their confinement. Id.
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