Court Denies Claim of Inadequate Access to Courts Based on Insufficient Law Library Materials and Assistance

In Williams v. Holder, the Northern District of New York recently dismissed plaintiff’s claim, brought under Section 1983 and Bivens, that he was denied meaningful access to the courts because the prison’s law library did not contain sufficient legal materials and he was not provided with adequate legal assistance.

The court summarized the law in this area:

[A]ccess to the courts is a fundamental right that requires prison authorities to “assist inmates in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law.” … More recently, the Supreme Court held that an inmate alleging a denial of access to the courts must show “actual injury” as a result of the deficient access to the courts.  … The cause of the injury must be the inadequacy of the access.  … A plaintiff must show that a non-frivolous claim has been frustrated or was being impeded by prison officials.  … Accordingly, a plaintiff must assert non-conclusory allegations demonstrating both (1) that the defendant acted deliberately and maliciously, and (2) that a non-frivolous legal claim has been frustrated or impeded as a result of the allegedly inadequate law library.

Plaintiff attempted to claim that he suffered an “actual injury” because, according to him, if he was provided with adequate materials and assistance, he would not have been “facing a term of 60-years” imprisonment”.

The Court disagreed:

[D]espite liberally construing the pleading, nothing in the amended complaint even suggests that proper access to legal materials and/or legal assistance would have provided plaintiff with a non-frivolous basis for defending that criminal proceeding.  Plaintiff’s wholly conclusory claim is simply insufficient to establish a constitutional violation of denial of meaningful access to the courts. Furthermore, as this Court noted in the April Decision and Order, it is clear that plaintiff was appointed defense counsel … prior to commencing this lawsuit. … Appointed counsel defeats plaintiff’s claim that the inadequate law library and legal assistance at the … [j]ail prejudiced his rights in his criminal action. … Moreover, plaintiff did not plead to the charges but, rather, was tried before a jury[.]

Thus the Court denied plaintiff’s “denial of access” claim without prejudice.  It did, however, find that plaintiff stated a claim that the law librarian retaliated against plaintiff by ignoring his requests for legal materials, but made clear that it was not expressing any opinion as to whether such a claim could “withstand a properly filed motion to dismiss or for summary judgment”.