Wednesday, November 6, 2013

Lewis v. Casey case brief

Lewis v. Casey case brief summary
518 U.S. 343 (1996)

Petitioner Arizona Department of Corrections (ADOC) sought review of a judgment of the United States Court of Appeals for the Ninth Circuit upholding an injunction ordering ADOC to provide meaningful access to prison law libraries in respondent prisoners' class action alleging that ADOC deprived prisoners of their rights of access to the courts and counsel as protected by the First, Sixth, and Fourteenth Amendments.

ADOC contended that the district court exceeded its authority in imposing an injunction that mandated sweeping changes in access to prison law libraries and legal assistance.


  • The Court found that actual injury was required to establish standing for a violation of constitutional rights, which meant a showing that the inmates were denied the tools required to attack their sentences, directly or collaterally, or to challenge conditions of their confinement. 
  • Apart from the district court's identification of two instances of actual injury to two inmates, there was no evidence that illiterate prisoners could not obtain the minimal help necessary to file claims. 
  • Thus, the district court's granting of a systemwide remedy improperly went beyond what was necessary to provide relief to the two inmates. 
  • The Court also found that the district court failed to accord adequate deference to the judgment of the prison authorities with respect to restrictions on lockdown prisoners' access to law libraries, that the injunction was inordinately intrusive, and that the order was developed through a process that failed to give adequate consideration to the views of state prison authorities.

The Court reversed the judgment of the court of appeals and remanded the case for further proceedings consistent with its opinion.

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