Bounds v. Smith (1977) This 1977 Supreme Court case held that, "the fundamental constitutional right of access to the courts 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" (Marshall, 1977). The Petitioners in the case, representatives from the State of North Carolina, had argued that prisoners were "ill-equipped to use the tools of the trade of the legal profession" and therefore providing law libraries to prisoners would not qualify as a means to providing meaningful access to the courts, and should therefore not be required (Marshall, 1977). In the decision, Justice Marshall stated that the Supreme Court's "experience indicates that pro se petitioners are capable of using lawbooks to file cases raising claims that are serious and legitimate even if ultimately unsuccessful" (Marshall, 1977). Marshall also reiterated in this decision that, "while adequate law libraries are one constitutionally acceptable method to assure meaningful access to the courts, our decision here...does not foreclose alternative means to achieve that goal" (Marshall, 1977). As an example the ruling states that offering professional or quasi-professional legal assistance to inmates would be another acceptable means to achieve that goal (Marshall, 1977). This Supreme Court case was very important in the history of prison libraries because it affirmed that prisoners did in fact have a right to either a law library or professional legal assistance in order to ensure they truly had fair access to the courts. It is important to note that this Supreme Court ruling only affirmed a prisoner's right to access a law library or professional/quasi-professional legal assistance, not any other type of reading material.
Lewis v. Casey (1996) This 1996 Supreme Court ruling "narrowed the interpretation of Bounds and limited the parameters under which state correctional agencies were obligated to provide inmates with legal assistance and resources" (Lehmann, 493). According to the ruling itself: "[R]espondents seem to assume, the right at issue--the right to which the actual or threatened harm must pertain--were the right to a law library or to legal assistance. But Bounds established no such right...Although it affirmed a court order requiring North Carolina to make law library facilities available to inmates, it stressed that that was merely 'one constitutionally acceptable method to assure meaningful access to the courts'...In other words, prison law libraries and legal assistance programs are not ends in themselves, but only the means for ensuring 'a reasonably adequate opportunity to present claimed violations of fundamental constitutional rights to the courts'...Because Bounds did not create an abstract, free standing right to a law library or legal assistance, an inmate cannot establish relevant actual injury simply by establishing that his prison's law library or legal assistance program is sub par in some theoretical sense." (Scalia, 1996). From my own reading of the rulings, I had the impression that Bounds v. Smith had established that prisoners had a right to access either an adequate law library or adequate legal assistance. However, the 1996 ruling held that actually an inmate "must go one step further and demonstrate that the alleged shortcomings in the library or legal assistance program hindered his efforts to pursue a legal claim" (Scalia, 1996). Essentially, the Court's ruling maintained that there was no "abstract, free standing right to a law library or legal assistance" for prisoners, but rather that a prisoner had to demonstrate actual injury in terms of not being able to gain "meaningful access to the court" resulting from an inadequate law library or legal assistance. In my opinion, this seems illogical because if an inmate does not have access to a law library or legal assistance, how would she be able to successfully go about filing the correct documents with the court to demonstrate that she did not have access to adequate legal materials or assistance? I think it would be much more difficult for a prisoner to prove this type of injury, because to prove the injury she would need to at least have enough understanding of the relevant law and courts to file such a claim in the first place, but without a law library or legal assistance that would seem to be quite a difficult thing to accomplish.
Beyond Legal Materials
Although, as far as my research was able to uncover, law libraries are the only type of libraries that prison inmates may have a legal right to access, it is worth noting that prisoners do have some rights to access other types of reading materials as well (although not necessarily in the form of a library). For example, in 2003, Sutton v. Rasheed held that prisoners had the right to access the vital texts associated with their religious beliefs, even if those texts may be considered non-religious or not to be the primary religious text of the religion by others (United States Court of Appeals, Third Circuit, 2003). This case specifically dealt with the Nation of Islam and whether or not certain texts associated with it were religious or non-religious, and whether or not they were vital texts to the religion (in addition to the Quran). The Court found that the prisoners did have a right to access these additional texts, and explained their decision by comparing Nation of Islam to Mormonism, which is a Christian denomination that uses a text in addition to the Bible (United States Court of Appeals, Third Circuit, 2003). The Court concluded that, "There can be no fault line in the Constitution that would place the followers of Jesus Christ and Joseph Smith on the preferred side of the line and the followers of Elijah Muhammad and Louis Farrakhan on the other side" (United States Court of Appeals, Third Circuit, 2003). Although this court case did not deal with prison libraries directly, I thought it was meaningful to add it to my discussion of court cases because it highlights the only other type of book that prisoners are guaranteed access to in addition to law books (or legal assistance), which is religious texts.